Geologic Sequestration of Carbon 

Dioxide

Draft Underground Injection Control 

(UIC) Program Class VI Well 

Recordkeeping, Reporting, and Data 

Management Guidance for Permitting 

Authorities
Office of Water (4606M) 

EPA 816-P-13-002

www.epa.gov/safewater

March 2013 
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Disclaimer 

The Class VI injection well classification was established by the Federal Requirements Under 

the Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic 

Sequestration (GS) Wells (75 FR 77230, December 10, 2010), referred to as the Class VI Rule, 

which establishes a new class of injection well (Class VI). 

The Safe Drinking Water Act (SDWA) provisions and the United States Environmental 

Protection Agency (EPA) regulations cited in this document contain legally-binding 

requirements. In several sections, this guidance document makes suggestions and offers 

alternatives that go beyond the minimum requirements indicated by the Class VI Rule. This is 

intended to provide information and suggestions that may be helpful for implementation efforts. 

Such suggestions are prefaced by “may” or “should” and are to be considered advisory. They are 

not required elements of the Rule. Therefore, this document does not substitute for those 

provisions or regulations, nor is it a regulation itself, so it does not impose legally-binding 

requirements on EPA, states, or the regulated community. The recommendations herein may not 

be applicable to each and every situation. 

EPA and state decision makers retain the discretion to adopt approaches on a case-by-case basis 

that differ from this guidance where appropriate. Any decisions regarding a particular facility 

will be made based on the applicable statutes and regulations. Mention of trade names or 

commercial products does not constitute endorsement or recommendation for use. EPA is taking 

an adaptive rulemaking approach to regulating Class VI injection wells, and the agency will 

continue to evaluate ongoing research and demonstration projects and gather other relevant 

information as needed to refine the Rule. Consequently, this guidance may change in the future 

without a formal notice and comment period. 

While EPA has made every effort to ensure the accuracy of the discussion in this document, the 

obligations of the regulated community are determined by statutes, regulations, or other legally 

binding requirements. In the event of a conflict between the discussion in this document and any 

statute or regulation, this document would not be controlling. 

Note that this document only addresses issues covered by EPA’s authorities under SDWA. Other 

EPA authorities, such as Clean Air Act (CAA) requirements to report carbon dioxide injection 

activities under the Greenhouse Gas Mandatory Reporting Rule (GHG MRR) are not within the 

scope of this document.
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Executive Summary

EPA’s Federal Requirements Under the Underground Injection Control (UIC) Program for 

Carbon Dioxide (CO2) Geologic Sequestration (GS) Wells, codified in the U.S. Code of Federal 

Regulations [40 CFR 146.81 et seq.], known as the Class VI Rule, establishes a new class of 

injection well, Class VI, and sets minimum technical criteria for Class VI injection wells for the 

purposes of protecting underground sources of drinking water (USDWs). This document is part 

of a series of guidance documents developed to support owners or operators of Class VI wells 

and the UIC Program permitting authorities. 

Under the Class VI Rule, owners or operators of Class VI wells are required to site, construct, 

and operate their wells according to the specific technical criteria that address specific GS 

activities: site characterization; area of review (AoR) delineation and corrective action; well 

construction and operation; financial responsibility; testing and monitoring; reporting and 

recordkeeping; post-injection site care (PISC) and site closure; and emergency and remedial 

response. Data management, recordkeeping, and reporting are important components of the UIC 

Program and help ensure that the activities and operations regulated under the program are 

conducted as planned, are compliant with the regulations and permit conditions, and, ultimately, 

are sufficiently protective of USDWs.

Additionally, EPA is implementing an adaptive rulemaking approach to the Class VI Rule, 

whereby the agency plans to collect and review data every six years on GS projects to determine 

whether the appropriate amount and types of information and appropriate documentation are 

being collected, as well as to determine if modifications to the requirements are necessary. 

Effective GS data management significantly impacts the effectiveness of this effort. 

This guidance closely references other UIC Program Class VI well guidance documents for 

technical details. In particular, the information provided in this guidance document complements 

the information given in the UIC Class VI Implementation Manual for State Directors and the

UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for 

Owners or Operators. This guidance document has been developed to provide information to 

and describe possible approaches for UIC Program Directors to address various aspects of 

reporting, recordkeeping, and data management associated with GS projects operating under the 

Class VI Rule. Additionally, the Class VI Rule, at 40 CFR 146.91(e), requires owners or 

operators of Class VI wells to report all submittals to EPA in an approved electronic format. As 

such, this guidance document also describes EPA’s electronic reporting and data management

system.

1 Following the introductory section, which describes the purpose and organization of 

this guidance document, Section 2 describes reporting, recordkeeping, and data management 

associated with UIC Program Directors’ activities that take place during the different phases of a 

1 At the time this draft document was published, the central data system for Class VI data was under development. 

To avoid publishing incomplete information, this draft contains a placeholder for the description of GS data 

management through the use of the central data system.
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GS project’s life cycle. Section 3 describes the centralized, integrated electronic reporting system 

maintained by EPA, and presents the overall electronic data submission procedures and data 

management operations for UIC Program Directors.
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Table of Contents

Disclaimer ..................................................................................................................................... iii

Executive Summary ..................................................................................................................... iv

Table of Contents ......................................................................................................................... vi

List of Tables .............................................................................................................................. viii

List of Figures ............................................................................................................................. viii

Acronyms and Abbreviations ..................................................................................................... ix

Definitions ...................................................................................................................................... x

1 Introduction ........................................................................................................................... 1

1.1 Importance of Effective Class VI Reporting and Data Management............................... 1

1.2 Purpose of Guidance ........................................................................................................ 2

1.3 Relationship to Other EPA Guidance............................................................................... 3

1.4 Organization of this Document ........................................................................................ 4

2 Reporting and Recordkeeping Associated with Permitting Authority Responsibilities 5

2.1 Pre-Injection Phase: Prior to Construction ....................................................................... 8

2.1.1 Class VI Well Permit Application ............................................................................ 8

2.1.2 Site Characterization ............................................................................................... 11

2.1.3 AoR and Corrective Action .................................................................................... 12

2.1.4 Financial Responsibility.......................................................................................... 14

2.1.5 Injection Well Construction .................................................................................... 15

2.1.6 Proposed Activities and Project Plans .................................................................... 16

2.1.7 Injection Depth Waivers ......................................................................................... 19

2.2 Pre-Injection Phase: Prior to Injection ........................................................................... 22

2.2.1 Site Characterization ............................................................................................... 22

2.2.2 Final AoR and Corrective Action Status ................................................................ 23

2.2.3 Injection Well Construction and Testing ................................................................ 24

2.2.4 Final Project Plans .................................................................................................. 26

2.3 Injection Phase ............................................................................................................... 27

2.3.1 Injection Well Operation......................................................................................... 27

2.3.2 Testing and Monitoring........................................................................................... 29

2.3.3 Reevaluation of AoR and Phased Corrective Action .............................................. 30

2.3.4 Project Plan Updates ............................................................................................... 32

2.3.5 Financial Responsibility Updates and Notifications ............................................... 34

2.3.6 Emergency and Remedial Response ....................................................................... 35

2.4 Post-Injection Phase ....................................................................................................... 36

2.4.1 Injection Well Plugging .......................................................................................... 36

2.4.2 PISC and Site Closure ............................................................................................. 38

2.4.3 Emergency and Remedial Response ....................................................................... 40

2.5 UIC Program Director Program Reporting to EPA ....................................................... 41
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2.6 Recordkeeping by the UIC Program Director ................................................................ 43

3 GS Data Submission and Management ............................................................................. 44

Appendix A. Draft Class VI Oversight and Compliance Data Elements Matrix ............... A-1
List of Tables

Table 2-1. Activities and submittals required under the Class VI Rule for the phases of a GS 

project............................................................................................................................................. 7

Table A-1. Class VI Rule oversight and compliance data elements matrix (DRAFT). .............. A-1

List of Figures 

Figure 2-1. The phases of a GS project’s life cycle with associated activities required by the 

Class VI Rule and the sections of this guidance document that address each activity.................... 6

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Acronyms and Abbreviations

AoR Area of review

CAA Clean Air Act

CFR Code of Federal Regulations

CO2 Carbon dioxide 

EPA Environmental Protection Agency 

GAO Government Accountability Office 

GHG MRR Greenhouse Gas Mandatory Reporting Rule 

GS Geologic sequestration

MIT Mechanical integrity test 

OMB Office of Management and Budget

PAM Program Activity Measure

PDF Portable document format 

PISC Post-injection site care

PWSS Public Water System Supervision 

QA/QC Quality assurance/quality control 

RCRA Resource Conservation and Recovery Act 

SDWA Safe Drinking Water Act

SNC Significant noncompliance 

TDS Total dissolved solids 

UIC Underground Injection Control 

USDW Underground source of drinking water 
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Definitions 

Key to definition sources: 

1: Class VI Rule Preamble

2: 40 CFR 144.3 

3: 40 CFR 146.81(d) 

4: This definition was drafted for the purposes of this document 

5: EPA’s UIC website (http://water.epa.gov/type/groundwater/uic/glossary.cfm) 

6: 40 CFR 144.6(f) and 144.80(f) 

Annulus means the space between the well casing and the wall of the borehole; the space 

between concentric strings of casing; the space between casing and tubing.1

Aquifer exemption refers to a special exemption that removes an aquifer or part of an aquifer 

from SDWA protection when certain requirements [at 40 CFR 146.4] are met to demonstrate that 

the exempted aquifer does not currently serve as source of drinking water and has no real 

potential to be used as drinking water source in the future. One basis for demonstrating that an 

aquifer will not be used in the future is to show that it is mineral producing or capable of mineral 

production.4

Area of review (AoR) means the region surrounding the geologic sequestration project where 

USDWs may be endangered by the injection activity. The area of review is delineated using 

computational modeling that accounts for the physical and chemical properties of all phases of 

the injected carbon dioxide stream and displaced fluids, and is based on available site 

characterization, monitoring, and operational data as set forth in 40 CFR 146.84.3

Automatic shut-off device refers to a valve coupled with a control device that closes the valve 

when a pre-determined set pressure or flow value is exceeded. Shut-off devices in injection wells 

can automatically shut down injection activities when operating parameters unacceptably diverge 

from permitted values.

4

Carbon dioxide plume means the extent underground, in three dimensions, of an injected 

carbon dioxide stream.3

Carbon dioxide stream means carbon dioxide that has been captured from an emission source 

(e.g., a power plant), plus incidental associated substances derived from the source materials and 

the capture process, and any substances added to the stream to enable or improve the injection 

process. This subpart [subpart H of 40 CFR 146] does not apply to any carbon dioxide stream 

that meets the definition of a hazardous waste as defined by the Resource Conservation and 

Recovery Act (RCRA) under 40 CFR part 261.3.3

Casing means pipe material placed inside a drilled hole to prevent the hole from collapsing. The 

two types of casing in most injection wells are (1) surface casing, the outer-most casing that 

extends from the surface to the base of the lowermost USDW and (2) long string casing, which 

extends from the surface to or through the injection zone.1
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Cement means material used to support and seal the well casing to the rock formations exposed 

in the borehole. Cement also protects the casing from corrosion and prevents movement of 

injectate up the borehole. The composition of the cement may vary based on the well type and 

purpose; cement may contain latex, mineral blends, or epoxy.1

Class I well means a technologically sophisticated well that injects wastes into deep, isolated 

rock formations below the lowermost USDW. Class I wells may inject hazardous waste, nonhazardous industrial waste, or municipal wastewater.5

Class II wells means wells that inject brines and other fluids associated with oil and gas 

production, or storage of hydrocarbons. Class II well types include salt water disposal wells, 

enhanced oil recovery wells, enhanced gas recovery wells, and hydrocarbon storage wells.5

Class V well means a well designed and constructed for injection, but not included in the 

definitions of Class I, II, III, IV, or VI wells. Class V wells inject non-hazardous fluids into or 

above a USDW and are typically shallow, on-site disposal systems; however, this class also 

includes some deeper injection operations. There are approximately 20 subtypes of Class V 

wells.5

Class VI wells means wells that are not experimental in nature that are used for GS of carbon 

dioxide beneath the lowermost formation containing a USDW; or, wells used for GS of carbon 

dioxide that have been granted a waiver of the injection depth requirements pursuant to 

requirements at 40 CFR 146.95; or, wells used for GS of carbon dioxide that have received an 

expansion to the areal extent of an existing Class II enhanced oil recovery or enhanced gas 

recovery aquifer exemption pursuant to 40 CFR 146.4 and 144.7(d).6

Computational code refers to a series of interrelated mathematical equations solved by 

computer to represent the behavior of a complex system. For the purposes of GS, computational 

models represent, at a minimum, the flow and transport of multiple fluids and components in 

varying phases through porous media. Computational codes offer the ability to predict fluid flow 

in the subsurface using scientifically accepted mathematical approximations and theory. The use 

of computational codes is necessary because the mathematical formulations describing fluid flow 

are complicated and in many cases, non-linear. Several codes have been specifically developed 

or tailored for injection activities similar to GS, and can be used for this purpose.4

Computational model means a mathematical representation of the injection project and relevant 

features, including injection wells, site geology, and fluids present. For a GS project, site specific 

geologic information is used as input to a computational code, creating a computational model 

that provides predictions of subsurface conditions, fluid flow, and carbon dioxide plume and 

pressure front movement at that site. The computational model comprises all model input and 

predictions (i.e., output). 4

Confining zone means a geologic formation, group of formations, or part of a formation 

stratigraphically overlying the injection zone(s) that acts as barrier to fluid movement. For Class 

VI wells operating under an injection depth waiver, confining zone means a geologic formation, 
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group of formations, or part of a formation stratigraphically overlying and underlying the 

injection zone(s).3

Corrective action means the use of UIC Program Director-approved methods to ensure that 

wells within the AoR do not serve as conduits for the movement of fluids into USDWs.3

Corrosive means having the ability to wear away a material by chemical action. Carbon dioxide 

mixed with water forms carbonic acid, which can corrode well materials.1

Enhanced gas recovery means the process of injecting a gas (i.e., carbon dioxide) into a gasbearing formation to displace available gas to allow it to be produced.4

Enhanced oil recovery means the process of injecting carbon dioxide into an oil reservoir to 

thin (decrease the viscosity) of extractable oil, which is then available for recovery.4 

Enhanced recovery means either enhanced oil recovery or enhanced gas recovery.4 

Fluid means any material or substance which flows or moves whether in a semisolid, liquid, 

sludge, gas or other form or state. 2

Formation or geological formation means a layer of rock that is made up of a certain type of 

rock or a combination of types.1

Geologic sequestration (GS) means the long-term containment of a gaseous, liquid, or 

supercritical carbon dioxide stream in subsurface geologic formations. This term does not apply 

to carbon dioxide capture or transport.3

Geologic sequestration project means an injection well or wells used to emplace a carbon 

dioxide stream beneath the lowermost formation containing a USDW; or, wells used for GS of 

carbon dioxide that have been granted a waiver of the injection depth requirements pursuant to 

requirements at 40 CFR 146.95; or, wells used for GS of carbon dioxide that have received an 

expansion to the areal extent of an existing Class II enhanced oil recovery or enhanced gas 

recovery aquifer exemption pursuant to 40 CFR 146.4 and 144.7(d). It includes the subsurface 

three-dimensional extent of the carbon dioxide plume, associated area of elevated pressure, and 

displaced fluids, as well as the surface area above that delineated region.3

Injectate means the fluids injected. For the purposes of the Class VI Rule, this is also known as 

the carbon dioxide stream.1

Injection depth waivers refer to the provisions at 40 CFR 146.95 that allow owners or operators 

to seek a waiver from the Class VI injection depth requirements for GS to allow injection into 

non-USDW formations while ensuring that USDWs are protected from endangerment.4

Injection zone means a geologic formation, group of formations, or part of a formation that is of 

sufficient areal extent, thickness, porosity, and permeability to receive carbon dioxide through a 

well or wells associated with a GS project.3
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Mechanical integrity means the absence of significant leakage within the injection tubing, 

casing, or packer (known as internal mechanical integrity), or outside of the casing (known as 

external mechanical integrity).

1

Mechanical integrity test (MIT) refers to a test performed on a well to confirm that a well 

maintains internal and external mechanical integrity. MITs are a means of measuring the 

adequacy of the construction of an injection well and a way to detect problems within the well 

system.1

Model means a representation or simulation of a phenomenon or process that is difficult to 

observe directly or that occurs over long time frames. Models that support GS can predict the 

flow of carbon dioxide within the subsurface, accounting for the properties and fluid content of 

the subsurface formations and the effects of injection parameters.

1

Owner or operator means the owner or operator of any facility or activity subject to regulation 

under the UIC program.2

Packer means a mechanical device that seals the outside of the tubing to the inside of the long 

string casing, isolating an annular space.1

Phased corrective action refers to a provision of the Class VI Rule [40 CFR 146.84(b)(2)(iv)] 

afforded to Class VI injection well owners or operators to defer some identified corrective action 

needed within the AoR, but farther away from the injection well, until after injection has 

commenced, but prior to carbon dioxide plume and pressure front movement into that particular 

area.4

Post-injection site care (PISC) means appropriate monitoring and other actions (including 

corrective action) needed following cessation of injection to ensure that USDWs are not 

endangered, as required under 40 CFR 146.93.3

Pressure front means the zone of elevated pressure that is created by the injection of carbon 

dioxide into the subsurface. For GS projects, the pressure front of a carbon dioxide plume refers 

to the zone where there is a pressure differential sufficient to cause the movement of injected 

fluids or formation fluids into a USDW.3

Primacy (primary enforcement responsibility) means the authority to implement the UIC 

Program. To receive primacy, a state, territory, or tribe must demonstrate to EPA that its UIC 

program is at least as stringent as the federal standards; the state, territory, or tribal UIC 

requirements may be more stringent than the federal requirements. (For Class II, states must 

demonstrate that their programs are effective in preventing pollution of USDWs.) EPA may grant 

primacy for all or part of the UIC program, e.g., for certain classes of injection wells.5

Site closure means the specific point or time, as determined by the UIC Program Director 

following the requirements under 40 CFR 146.93, at which the owner or operator of a GS site

(Class VI injection well) is released from PISC responsibilities.3
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Total dissolved solids (TDS) refers to the measurement, usually in mg/L, for the amount of all 

inorganic and organic substances suspended in liquid as molecules, ions, or granules. For 

injection operations, TDS typically refers to the saline (i.e., salt) content of water-saturated 

underground formations. 1

Transmissive fault or fracture means a fault or fracture that has sufficient permeability and 

vertical extent to allow fluids to move between formations.3

Tubing refers to a small-diameter pipe installed inside the casing of a well. Tubing conducts 

injected fluids from the wellhead at the surface to the injection zone and protects the long string 

casing of a well from corrosion or damage by the injected fluids.5

Underground Injection Control (UIC) Program refers to the program EPA, or an approved 

state, is authorized to implement under the SDWA that is responsible for regulating the 

underground injection of fluids by wells injection. This includes setting the federal minimum 

requirements for construction, operation, permitting, and closure of underground injection wells.4

Underground Injection Control (UIC) Program Director refers to the chief administrative 

officer of any state or tribal agency or EPA Region that has been delegated to operate an 

approved UIC program.5

Underground source of drinking water (USDW) means an aquifer or portion of an aquifer that 

supplies any public water system or that contains a sufficient quantity of ground water to supply 

a public water system, and currently supplies drinking water for human consumption, or that 

contains fewer than 10,000 mg/L TDS and is not an exempted aquifer.1

Well bore refers to the hole that remains throughout a geologic (rock) formation after a well is 

drilled.4

Workover refers to any maintenance activity performed on a well that involves ceasing injection

or production and removing the wellhead.4
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1 Introduction 

To ensure the protection of underground sources of drinking water (USDWs), the United States

Environmental Protection Agency (EPA) established minimum federal requirements for the 

proper management of carbon dioxide injection and storage under the authority of Part C of the 

Safe Drinking Water Act (SDWA) in December 2010. The Federal Requirements Under the 

Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic 

Sequestration (GS) Wells, found at 75 FR 77230 and hereafter referred to as the Class VI Rule, 

requires well owners or operators to collect, generate, and report specific information needed to 

inform permitting decisions and decisions related to siting, constructing, operating, monitoring, 

and closing a Class VI well [40 CFR 146.81 et seq.]. 

The Class VI Rule defines a new class of injection wells, Class VI, along with technical criteria 

that tailor the UIC Program’s existing regulatory framework to address the unique nature of 

carbon dioxide injection for geologic sequestration (GS). These technical criteria address 

different components of a GS project: site characterization; area of review (AoR) delineation and 

corrective action; well construction and operation; financial responsibility; testing and 

monitoring; reporting and recordkeeping; post-injection site care (PISC) and site closure; and 

emergency and remedial response. Figure 2-1 presents a general sequence of these specific 

activities within a GS project workflow. 

Under the Class VI Rule, UIC Program Directors have oversight responsibilities related to 

permitting, implementation, and compliance under the UIC Program. For UIC Programs 

administered by EPA, the UIC Program Director is the EPA Regional Administrator or his/her

designee; for UIC Programs in primacy states, tribes, or territories, the UIC Program Director is 

the state agency responsible for permitting, implementation, and compliance of the state, tribal, 

or territorial UIC Program. The oversight responsibilities of the UIC Program Director are to 

ensure that owners or operators of Class VI wells properly site, operate, monitor, and close their 

wells in a manner that protects USDWs. These responsibilities include reviewing permit

applications and writing permits, authorizing injection, reviewing testing and monitoring results 

during the injection and post-injection phases, addressing compliance issues, and approving site 

closure. Reporting, recordkeeping, and data management are an integral part of documenting and 

demonstrating effective oversight by the UIC Program and safe deployment of underground 

injection operations and protection of USDWs. 

1.1 Importance of Effective Class VI Reporting and Data Management 

The Class VI Rule, at 40 CFR 146.91(e), requires owners or operators of Class VI wells to 

submit all reports in an electronic format approved by EPA. Given the nature of Class VI well 

operations and the more comprehensive requirements of the Class VI Rule compared to those for 

other UIC well classes, the Interagency Task Force on Carbon Capture and Storage 

recommended the use of “a national data system that would promote regulatory certainty, 

efficiency, and accountability, while allowing transparency of all geologic sequestration related 
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information.”2 Therefore, all of the data required under the Class VI Rule must be submitted to 

and retained in an EPA data system, regardless of whether the well is in a state that has primacy. 

The UIC Program Directors will use this data system to access and manage the GS data 

submitted by owners or operators of Class VI wells. 

Additionally, EPA is implementing an adaptive rulemaking approach to the Class VI Rule, 

whereby EPA plans to collect and review data every six years on GS projects to determine 

whether the appropriate amount and types of information and documentation are being collected, 

and to determine if modifications to the requirements are necessary. Successful GS data 

management through the use of an electronic data system helps facilitate and significantly 

improve the effectiveness of GS efforts. 

Furthermore, information on the performance of Class VI wells that is managed by a central, 

integrated data system will help EPA evaluate the success of the Class VI Program by allowing 

tracking, evaluating, and reporting on program performance. The information will also enable

EPA to respond to information requests and perform analyses for Congress, the public, and other 

interested parties. This information also enables the UIC Program Director to substantiate and 

provide the rationale behind decisions related to compliance or a determination of USDW 

endangerment. Pursuant to the requirements under 40 CFR 144.8, an owner or operator’s failure 

to comply with site-specific permit conditions, complete construction as specified in the UIC 

permit, provide compliance schedules or monitoring reports, or submit complete reports is 

considered to be an instance of noncompliance and a violation of the permit under Section 1423 

of SDWA. Similarly, an owner or operator’s performance of any action that causes USDW 

endangerment during the life of the GS project would also be considered noncompliance and a 

violation of the permit. EPA may use information submitted as evidence of an imminent and 

substantial endangerment of a USDW, which may require remedial action under Section 1431 of 

SDWA. 

1.2 Purpose of Guidance

As part of a series of guidance documents that provide information on Class VI well operations 

that are protective of USDWs and comply with the Class VI Rule, the purpose of this guidance is 

to provide: 

• A comprehensive description of reporting and recordkeeping recommendations

associated with permitting authority responsibilities for each phase of a GS operation (see

Figure 2-1).

• Information on how the reporting, recordkeeping, and data management activities will

ensure USDW protection, inform the adaptive approach, support compliance

determinations and national program oversight, and meet interagency data needs.

2 Interagency Task Force on Carbon Capture and Storage. 2010. Report of the Interagency Task Force on Carbon 

Capture and Storage, p. C-8. Available on the Internet at: http://www.epa.gov/climatechange/downloads/CCS-TaskForce-Report-2010.pdf. 
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• A comprehensive description of EPA’s central data system used for the purpose of

reporting, recordkeeping, and data management by permitting authorities.

This guidance does not provide information or recommendations on how UIC Program Directors 

can make decisions that are protective of USDWs. Information on the UIC Program Director’s 

evaluation and considerations for decision-making related to issuing permits, reviewing testing 

and monitoring results, evaluating AoR reevaluations and plan updates, and authorizing site 

closure can be found in the UIC Program Class VI Implementation Manual for State Directors. 

EPA recommends that UIC Program Directors utilize both this reporting guidance and the UIC

Program Class VI Implementation Manual for State Directors to gain a comprehensive 

understanding of their responsibilities. 

1.3 Relationship to Other EPA Guidance

This document is one of a series of guidance documents intended to provide information and 

possible approaches to UIC Program Directors for addressing various aspects of reporting, 

recordkeeping, and data management associated with GS projects operating under the Class VI 

Rule. As this guidance document closely references the UIC Program Class VI Implementation 

Manual for State Directors, it also complements the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Owners or Operators. Cross-linkages between 

guidance documents are noted in the text where appropriate. These additional UIC Program 

Class VI guidance documents can be found, when available, on EPA’s website 

at http://water.epa.gov/type/groundwater/uic/class6/gsguidedoc.cfm: 

• UIC Program Class VI Financial Responsibility Guidance.

• UIC Program Class VI Implementation Manual for State Directors.

• UIC Program Class VI Primacy Manual for State Directors.

• UIC Program Class VI Well Area of Review Evaluation and Corrective Action Guidance.

• UIC Program Class VI Well Construction Guidance.

• UIC Program Class VI Well Injection Depth Waivers Guidance.

• UIC Program Class VI Well Project Plan Development Guidance.

• UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance

for Owners or Operators.

• UIC Program Class VI Well Site Characterization Guidance.

• UIC Program Class VI Well Testing and Monitoring Guidance.

• UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site

Closure.
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• UIC Program Guidance on Transitioning Class II Wells to Class VI Wells.

1.4 Organization of this Document 

Following this introduction, the remainder of this document is organized as follows: 

• Section 2, Reporting and Recordkeeping Associated with Permitting Authority

Responsibilities, presents the specific information to be documented (e.g., compliance,

enforcement, violation, etc.) by UIC Program Directors under the Class VI Rule with

additional information on reporting timeframes and record retention requirements.

• Section 3, GS Data Submission and Management, describes the centralized, integrated

electronic reporting system maintained at EPA and presents the overall data submission

procedures and data management operations for UIC Program permitting authorities. It

also addresses all aspects of interagency data management operations employed within

the reporting system.

3

Table A-1 in Appendix A summarizes the information provided in Section 2 in a table of 

oversight and compliance data elements that EPA recommends UIC Program Directors 

document during the lifetime of a GS project. 

3 At the time this draft document was published, the central data system for Class VI data was under development. 

To avoid publishing incomplete information, this draft contains a placeholder for the description of GS data 

management through the use of the central data system.
Draft UIC Program Class VI Well Recordkeeping, 5 March 2013 

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for Permitting Authorities

2 Reporting and Recordkeeping Associated with Permitting

Authority Responsibilities

The Class VI Rule sets forth minimum federal requirements to protect USDWs from 

endangerment during underground injection of carbon dioxide for the purpose of GS. These 

requirements are tailored to address different phases of a GS project: pre-injection, injection, and 

post-injection (Figure 2-1, Table 2-1). During the lifecycle of a GS project, permitting authorities 

are responsible for ensuring that: 

• Each Class VI project is sited and planned such that USDWs are protected, considering

site- and project-specific information in the pre-injection phase.

• Class VI wells are operating as planned, in compliance with the regulations and as

verified by testing and monitoring, and in a way that is protective of USDWs during the

injection phase.

• PISC is conducted until there is no risk of endangerment to USDWs resulting from Class

VI well activities.

To achieve these goals, UIC Program Directors will receive and evaluate information submitted 

by owners or operators, perform required notifications, and provide critical information about 

their oversight responsibilities to EPA. The final decision regarding the appropriateness and 

acceptability of all owner or operator submissions rests with the UIC Program Director.

This section describes EPA’s recommendations regarding the information to be documented and 

reported by the UIC Program Director to support compliance and oversight decisions, GS data

management, and the adaptive rulemaking process. This information includes: 

• The UIC Program Director’s decisions with regard to the issuance of permits, oversight,

and compliance.

• Responses to owner or operator submissions.

• Information necessary for national program oversight and the adaptive rulemaking

approach.
Draft UIC Program Class VI Well Recordkeeping, 6 March 2013 

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for Permitting Authorities

Figure 2-1. The phases of a GS project’s life cycle with associated activities required by the Class VI Rule and the sections of this guidance document 

that address each activity.
Draft UIC Program Class VI Well Recordkeeping, 7 March 2013 

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for Permitting Authorities

Table 2-1. Activities and submittals required under the Class VI Rule for the phases of a GS project.

GS Project Phase Activities/Submittals and Relevant Sections of this Document

Pre-injection 

(before construction)

• Class VI well permit application: Section 2.1.1

• Site characterization data and proposed pre-operational formation testing

program: Section 2.1.2

• AoR delineation and corrective action, including the proposed AoR and

Corrective Action Plan: Section 2.1.3

• Financial responsibility demonstration: Section 2.1.4

• Proposed injection well construction procedures, schematics, drawings, and

stimulation program: Section 2.1.5

• Proposed activities and project plans: Section 2.1.6

o Proposed operating data and procedures

o Proposed Testing and Monitoring Plan

o Proposed Injection Well Plugging Plan

o Proposed PISC and Site Closure Plan and, at the UIC Program Director’s

discretion, a demonstration of an alternative PISC timeframe

o Proposed Emergency and Remedial Response Plan

• Documentation for wells transitioning from Class II to Class VI:

Section 2.1.1.1

• Injection depth waiver application report: Section 2.1.7

Pre-injection 

(before operation)

• Updated site characterization data and pre-operational formation testing

program results: Section 2.2.1

• Final AoR documentation and status of corrective action: Section 2.2.2

• Injection well construction and testing documentation: Section 2.2.3

• Final project plans: Section 2.2.4

Injection • Injection well operation data: Section 2.3.1

• Testing and monitoring results: Section 2.3.2

• Documentation of AoR reevaluation and phased corrective action:

Section 2.3.3

• Project plan and alternative PISC timeframe demonstration updates:

Section 2.3.4

• Financial responsibility updates and notifications: Section 2.3.5

• Documentation of any emergency events and associated remedial response

activities: Section 2.3.6

Post-injection • Injection well plugging report: Section 2.4.1

• PISC monitoring results, non-endangerment demonstration, and site closure

notifications and report: Section 2.4.2

• Documentation of any emergency events and associated remedial response

activities: Section 2.4.3
Draft UIC Program Class VI Well Recordkeeping, 8 March 2013 

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for Permitting Authorities

2.1 Pre-Injection Phase: Prior to Construction 

Under the Class VI Rule, UIC Program Directors will receive submittals prior to the construction 

of a new Class VI well or the conversion of an existing Class I, Class II, or Class V experimental 

technology well to a Class VI well during the pre-injection phase as required at 40 CFR 

146.82(a) through (d). Based on this information, the UIC Program Director will determine 

whether to issue a Class VI permit. This section describes the UIC Program Director’s

recommended reporting and data management activities that occur prior to injection well 

construction or conversion (see Table 2-1). 

2.1.1 Class VI Well Permit Application 

The permit application for a Class VI well is composed of submittals documenting the activities 

conducted and/or proposed by owners or operators as required under 40 CFR 146.82(a). These 

activities are related to site characterization, AoR delineation and corrective action, injection 

well construction, and demonstration of financial responsibility. Additional submittals include 

proposed project plans and descriptions of proposed activities as presented in Table 2-1. 

The UIC Program Director must evaluate permit applications submitted by owners or operators 

to determine whether the application is complete and that the proposed project will not endanger 

USDWs. The permit application and evaluation process is an iterative one, which EPA expects to 

begin with “pre-application” communication between the UIC Program Director and the owner 

or operator of a proposed GS project. A detailed checklist of all required Class VI permit 

application materials is given in the UIC Program Class VI Implementation Manual for State 

Directors, along with descriptions of how the UIC Program Director will evaluate this 

information. Reporting and recordkeeping requirements specific to owners or operators during 

the permit application process are discussed in the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Owners or Operators. In addition, UIC Program 

Directors may use their discretion to request any additional information needed to support their 

evaluation and ensure that the proposed Class VI project is protective of USDWs [40 CFR 

146.82(a)(21)]. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information associated with their evaluations of Class 

VI permit applications: 

• The date that the permit application was received.

• The name and contact information of the applicant and other relevant project staff.

• The project name and duration.

• A determination of whether the permit application is complete or a description of

identified deficiencies. (Under 40 CFR 124.3(c), each application for an EPA-issued

permit submitted for a new UIC injection well should be reviewed for completeness by

the EPA Regional Administrator within 30 days of its receipt.)
Draft UIC Program Class VI Well Recordkeeping, 9 March 2013 

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• A determination of whether the information provided in the permit application is

accurate, in compliance with the requirements of the Class VI Rule, and demonstrates

that the proposed operation will not endanger any USDWs, or a determination that

additional information is needed. Examples of deficiencies may include, but are not

limited to:

o Need for additional site characterization information (see Section 2.1.2).

o Incomplete maps or cross sections of the AoR and/or tabulation of all wells that

penetrate the injection or confining zone(s) (e.g., the map omits other injection

wells; see Section 2.1.3).

o Insufficient demonstration of financial responsibility (see Section 2.1.4).

o Need for additional information on injection well construction (see Section 2.1.5).

o Incomplete proposed project plans or injection well operation data (see Section

2.1.6). 

o Insufficient demonstration of an alternative PISC timeframe, if one is proposed

(see Section 2.1.6).

o Incomplete list of contacts for states, tribes, and territories within the AoR.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

Following review of the permit application, the UIC Program Director will draft the Class VI 

permit, which authorizes the owner or operator to construct the well and provides preliminary 

operating and monitoring requirements. The Class VI Rule, at 40 CFR 146.82(b), requires UIC 

Program Directors to notify states, tribes, and territories within the AoR based on the information 

provided by the owner or operator. In addition, the UIC Program Director will also notify the 

public according to the public notification requirements in 40 CFR 124.10, and retain 

administrative records pursuant to 40 CFR 124.9 for draft permits when EPA is the permitting 

authority. 

2.1.1.1 Re-Permitting of Injection Wells 

Owners or operators of wells injecting carbon dioxide for enhanced recovery must apply for a 

Class VI permit if a determination is made that the primary purpose of the project is long-term 
Draft UIC Program Class VI Well Recordkeeping, 10 March 2013 

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for Permitting Authorities

storage of carbon dioxide and that there is an increased risk to USDWs compared to Class II 

operations [40 CFR 144.19].Owners or operators of existing Class V experimental technology 

wells that seek to use their wells to inject carbon dioxide for long-term storage must also apply 

for a Class VI permit. Re-permitting of injection wells is described in detail in both the UIC 

Program Class VI Implementation Manual for State Directors and the UIC Program Guidance 

on Transitioning Class II Wells to Class VI Wells.

For the purposes of re-permitting, the well owner or operator must submit a Class VI permit 

application and comply with all Class VI requirements under 40 CFR 146. However, certain 

elements of the well construction may be grandfathered. Pursuant to 40 CFR 146.81(c), an owner 

or operator may choose to demonstrate that a converted well was engineered and constructed to 

meet the requirements at 40 CFR 146.86(a) and will ensure protection of USDWs, in lieu of 

meeting the requirements at 40 CFR 146.86(b) and 146.87(a). EPA recommends that the UIC 

Program Director document the following information for oversight and compliance purposes 

resulting from their evaluations of these demonstrations: 

• A determination whether the demonstration is sufficient to approve the grandfathering of

certain components of the injection well and a description of these components.

• A description of identified deficiencies or information needs with regard to the

demonstration.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

In addition, owners or operators converting Class II wells that inject into exempted aquifers may 

request, before or concurrent with the Class VI permit application, to expand the areal extent of a 

previously approved aquifer exemption [40 CFR 144.7(d)]. The UIC Program Guidance on 

Transitioning Class II Wells to Class VI Wells describes the UIC Program Director’s evaluation 

of such a request. No designation of an expansion to the areal extent of a Class II enhanced 

recovery aquifer exemption for GS will be final unless approved by the EPA Regional 

Administrator as a revision to the applicable federal UIC Program under 40 CFR 147 or as a 

substantial revision of an approved state UIC Program under 40 CFR 145.32. For compliance 

and oversight purposes, EPA recommends that the UIC Program Director document the 

following information related to an aquifer expansion request: 

• A determination of whether the submitted information for the aquifer expansion request

is complete, or a description of any identified deficiencies in the submitted information.
Draft UIC Program Class VI Well Recordkeeping, 11 March 2013 

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for Permitting Authorities

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Correspondences with the EPA Regional Administrator about the proposed aquifer

exemption expansion, the decision of the EPA Regional Administrator, and the date of

the decision.

• Any additional compliance or oversight information.

2.1.2 Site Characterization

The Class VI Rule, at 40 CFR 146.82(a), requires owners or operators of Class VI wells to 

submit certain site characterization information prior to the issuance of a permit for the 

construction or conversion of a Class VI well. This site characterization information includes an 

assessment of the geologic, geomechanical, and hydrogeologic characteristics of the proposed 

storage site and overlying formations; a tabulation of all wells within the AoR; information on 

USDWs; baseline geochemical data; and a proposed program for pre-operational formation 

testing. Detailed information on performing site characterization activities is given in the UIC 

Program Class VI Well Site Characterization Guidance, and a description of the specific 

submittals made by owners or operators is given in the UIC Program Class VI Well 

Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. 

EPA recommends that, for the purpose of ensuring complete and consistent compliance and 

oversight evaluations, as well as supporting the adaptive rulemaking approach for the Class VI 

Rule, UIC Program Directors document the following information resulting from their 

evaluations of the site characterization information in the permit application: 

• Documentation that all of the materials required under 40 CFR 146.82(a)(2) through (6)

are present and are of acceptable quality.

• A description of any identified deficiencies or concerns. Examples of such deficiencies

may include, but are not limited to:

o Missing information required under 40 CFR 146.82(a)(2) through (6).

o Poor data quality or insufficient documentation of quality assurance/quality

control (QA/QC) procedures.

o Poorly constructed or labeled maps or cross sections.

o Unsuitable data collection methods for the samples or site.
Draft UIC Program Class VI Well Recordkeeping, 12 March 2013 

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for Permitting Authorities

o Insufficient documentation of test procedures or results.

o Inconsistencies among data types or concerns over ambiguous interpretations of

geologic data.

o Concerns regarding the suitability of the site (e.g., integrity of the confining zone,

capacity of the injection zone, seismicity, formation geochemistry).

• Documentation that any technical concerns regarding the site characterization

information have been resolved.

• Determination that the site is suitable for GS (pending the results of the formation testing

program) or, if technical concerns cannot be resolved, a decision that the site is unsuitable

for GS.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.1.3 AoR and Corrective Action

The Class VI Rule, at 40 CFR 146.84, requires owners or operators of Class VI wells to prepare, 

maintain, and comply with a plan to delineate the AoR for a proposed GS project, periodically 

reevaluate the delineation, and perform corrective action on all deficient wells in the AoR. 

Detailed information on performing AoR modeling and delineation, corrective action, and 

periodic AoR reevaluations is given in the UIC Program Class VI Well Area of Review 

Evaluation and Corrective Action Guidance. Submissions made by owners or operators to fulfill 

reporting requirements for AoR delineation and corrective action, along with record retention 

requirements, are described in the UIC Program Class VI Well Recordkeeping, Reporting, and 

Data Management Guidance for Owners or Operators. 

Prior to the authorization of Class VI well construction, the UIC Program Director’s 

responsibilities include reviewing the proposed AoR and Corrective Action Plan, the initial AoR 

delineation, and the identification of corrective action needs. During his or her review, the UIC 

Program Director will evaluate the AoR and Corrective Action Plan to ensure that it is consistent 

with the available site-specific data and proposed operational information, that it includes all 

relevant artificial penetrations, and that the AoR reevaluation schedule and the conditions that 

would warrant a reevaluation of the AoR are appropriately identified. Furthermore, the UIC 

Program Director will ensure that the AoR delineation is conducted in a way that is compliant 

with the Class VI Rule requirements. Detailed recommendations and considerations for 
Draft UIC Program Class VI Well Recordkeeping, 13 March 2013 

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for Permitting Authorities

conducting this evaluation are given in the UIC Program Class VI Implementation Manual for 

State Directors. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations: 

• For the AoR and Corrective Action Plan (in addition to the considerations applicable to

all project plans, which are addressed in Section 2.1.6):

o A determination of whether the list of wells requiring corrective action is

complete, based on the UIC Program Director’s knowledge of pertinent well

databases and preliminary information on the AoR (i.e., an assessment of whether

the owner or operator consulted all applicable information sources).

o Approval of the schedule for AoR reevaluations.

o If applicable, the approval decision for phased corrective action, including

specific well identification information and the proposed schedule for conducting

corrective action.

o Any identified site-specific and/or operational triggers for AoR reevaluations

prior to the next scheduled reevaluation.

• For the AoR delineation:

o A description of any deficiencies identified in the AoR delineation. Examples of

such deficiencies may include, but are not limited to:

 Inconsistencies identified between the information used in modeling and

site- and operation-specific data.

 Use of a computational code that does not appropriately account for the

physical and chemical characteristics of the injectate.

 Failing to account for other significant influences on subsurface pressures

and fluid movements, such as other injection activities.

o The name of the computational code the owner or operator used for the AoR

delineation.

o The simulation period used in modeling for final AoR delineation as submitted by

the owner or operator.

o A decision on the appropriateness and compliance of the modeling approach with

the Class VI Rule.

o Information on contractors used by the owner or operator, if applicable and

provided.
Draft UIC Program Class VI Well Recordkeeping, 14 March 2013 

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for Permitting Authorities

o Information on contractors used by the UIC Program Director, if applicable.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.1.4 Financial Responsibility

The Class VI Rule, at 40 CFR 146.85, requires owners or operators of Class VI wells to 

demonstrate and maintain financial responsibility for corrective action, injection well plugging, 

PISC, site closure, and emergency and remedial response. Detailed information on these 

requirements and the associated reporting and recordkeeping by owners or operators is provided 

in the UIC Program Class VI Financial Responsibility Guidance and the UIC Program Class VI 

Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. 

The qualifying financial responsibility instrument(s) must be approved by the UIC Program 

Director as a part of the initial financial responsibility demonstration. The UIC Program Director 

must consider and approve the financial responsibility demonstration for all phases and may 

disapprove a financial instrument if it is not sufficient to fulfill obligations as established in the 

initial cost estimate. Detailed recommendations for conducting this evaluation and a summary of 

the applicable considerations are given in the UIC Program Class VI Well Implementation 

Manual for State Directors. 

For the purpose of complete and consistent compliance and oversight evaluations and supporting 

the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Program 

Directors document the following information resulting from their evaluations of initial financial 

responsibility demonstrations: 

• A determination whether the proposed financial responsibility instrument(s) are from the

list of qualifying instruments.

• A description of any deficiencies identified in the financial responsibility demonstration.

Examples of such deficiencies may include, but are not limited to:

o Instruments based on performance are combined with payment instruments.

o Third-party providers do not meet minimum requirements.

o A standby trust fund is not established for select third-party instruments.

o Minimum requirements are not met for self insurance, if applicable.
Draft UIC Program Class VI Well Recordkeeping, 15 March 2013 

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for Permitting Authorities

o The length of the pay-in period for trust funds and escrow accounts is insufficient.

• A determination of whether the qualifying instrument(s) are sufficient to cover required

activity costs, are sufficient to address endangerment of USDWs, and comprise protective

conditions of coverage.

• A determination of whether the cost estimate is complete and compliant with the

requirements.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.1.5 Injection Well Construction

The Class VI Rule, at 40 CFR 146.86, requires owners or operators to construct wells that will 

prevent movement of fluids into unauthorized zones, permit use of appropriate testing devices 

and workover tools, and allow monitoring of the annulus between the tubing and casing. The 

Rule also provides specific requirements regarding the casing, cement, tubing, and packer, 

intended to prevent such fluid movement. Details on injection well construction requirements for 

Class VI wells are provided in the UIC Program Class VI Well Construction Guidance, and 

reporting and recordkeeping requirements for owners or operators are discussed in the UIC 

Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners 

or Operators.

Prior to the construction of the injection well, the owner or operator must submit proposed 

construction schematics and procedures [40 CFR 146.82(a)(11) and (12)]. Additionally, the 

owner or operator must submit a plan for stimulation procedures, if stimulation is to be 

performed [40 CFR 146.82(a)(9)]. The UIC Program Director’s responsibilities include 

reviewing construction plans and procedures for completeness and to ensure that the goals of 

preventing fluid movement, allowing testing and workover equipment, allowing monitoring of 

the annulus, and ensuring mechanical integrity for the life of the well are met. The UIC Program 

Class VI Implementation Manual for State Directors can be consulted for further information on 

the UIC Program Director’s evaluations. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations of 

proposed injection well construction submittals: 
Draft UIC Program Class VI Well Recordkeeping, 16 March 2013 

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• A determination of whether the proposed injection well construction procedures,

schematics, and drawings sufficiently address all requirements related to the casing,

cement, tubing, and packer and would prevent USDW endangerment.

• A determination of approval of the proposed stimulation program.

• A description of any identified deficiencies or concerns. Examples of such deficiencies

may include, but are not limited to:

o Poorly constructed or labeled schematics and drawings.

o Insufficient information to approve casing size, material, and strength.

o Insufficient information on the volume of cement, cementing procedures, or the

compatibility of cement materials with the injectate and formation fluids.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.1.6 Proposed Activities and Project Plans

The Class VI Rule requires owners or operators to submit a set of proposed project plans as part 

of the permit application [40 CFR 146.82(a)(13), (15), (16), (17), and (19)]. These plans are: 

• An AoR and Corrective Action Plan that meets the requirements of 40 CFR 146.84.

• A Testing and Monitoring Plan that meets the requirements of 40 CFR 146.90.

• An Injection Well Plugging Plan that meets the requirements of 40 CFR 146.92(b).

• A PISC and Site Closure Plan that meets the requirements of 40 CFR 146.93(a).

• An Emergency and Remedial Response Plan that meets the requirements of 40 CFR

146.94(a).

Section 2.1.3 describes some specific considerations for the AoR and Corrective Action Plan. 

Details on the development of all of the project plans are provided in the UIC Program Class VI 

Well Project Plan Development Guidance. It is the UIC Program Director’s responsibility to 

review and approve the proposed project plans, including communicating with the owner or 

operator regarding any additional information necessary to support and evaluate the plans. 
Draft UIC Program Class VI Well Recordkeeping, 17 March 2013 

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For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations of the 

proposed project plans: 

• A determination of whether the proposed plans are complete and in compliance with the

requirements of the Class VI Rule as cited above.

• Any deficiencies in the plans based on the UIC Program Director’s review. Examples of

such deficiencies may include, but are not limited to:

o The AoR and Corrective Action Plan does not contain a sufficient description of

the method for delineating the AoR, the AoR reevaluation schedule, the

conditions that would warrant a reevaluation or model calibration, or how

corrective action will be conducted.

o The Testing and Monitoring Plan does not consider site access for future activities

or does not sufficiently describe procedures for injectate monitoring, mechanical

integrity testing (MIT), corrosion monitoring, plume and pressure front

monitoring, monitoring geochemical changes in the subsurface, or, if required by

the UIC Program Director, surface air and/or soil gas monitoring.

o The Injection Well Plugging Plan does not include a description of appropriate

tests or measures to determine bottom-hole reservoir pressure or ensure external

mechanical integrity; the type and number of plugs; the placement of each plug;

the type, grade, and quantity of material to be used in plugging; or the method of

plug placement.

o The PISC and Site Closure Plan does not include sufficient information on the

differential between pre-injection and predicted post-injection pressures, the

predicted position of the plume and pressure front, or post-injection monitoring

locations, methods, and frequency.

o The Emergency and Remedial Response Plan does not contain a complete list of

potentially impacted environmental resources and risk scenarios, or identified

response actions and personnel and equipment to implement the response actions.

o Any plan does not adequately address site-specific considerations identified

elsewhere in the permit application.

• The result of the UIC Program Director’s evaluation and the date of the determination.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.
Draft UIC Program Class VI Well Recordkeeping, 18 March 2013 

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o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

Pursuant to 40 CFR 146.93(c), the owner or operator may include in the PISC and Site Closure 

Plan a proposed alternative PISC timeframe (i.e., a timeframe other than 50 years). The UIC 

Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site Closure

provides more information on the requirements for demonstrating that an alternative PISC 

timeframe is appropriate and the UIC Program Class VI Implementation Manual for State 

Directors includes considerations for the UIC Program Director’s evaluation. 

In evaluating an alternative PISC timeframe demonstration, the UIC Program Director must 

determine if the demonstration meets the criteria under 40 CFR 146.93(c)(2). EPA recommends 

that UIC Program Directors document the following information resulting from their 

evaluations: 

• The proposed alternative PISC timeframe (i.e., the number of years).

• A determination of whether the PISC timeframe demonstration is complete, and that all

documentation required under 40 CFR 146.93(c)(1) is present and acceptable.

• A description of any identified deficiencies or concerns, and whether the information

submitted meets the criteria under 40 CFR 146.93(c)(2).

• The result and date of the UIC Program Director’s determination.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

In addition to the proposed GS project plans, owners or operators must also submit proposed 

operating parameters and procedures for the Class VI project, and the steps necessary to conduct 

the injection operation [40 CFR 146.82(a)(9) and (10)]. This submission is described in the UIC 

Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners 

or Operators, and the UIC Program Class VI Implementation Manual describes considerations 

for the UIC Program Director’s Review.

EPA recommends that UIC Program Directors document the following information resulting 

from their evaluations of the proposed operating data: 
Draft UIC Program Class VI Well Recordkeeping, 19 March 2013 

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• A determination of whether the proposed operating data is complete pursuant to the

requirements at 40 CFR 146.82(a)(7).

• A description of any identified deficiencies or concerns (e.g. the proposed injection

pressure or anticipated carbon dioxide volumes seem inconsistent with submitted site

characterization data).

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.1.7 Injection Depth Waivers

Concurrently with the permit application process, owners or operators may seek a waiver of the 

Class VI Rule requirement to inject beneath the lowermost USDW [40 CFR 146.95]. Waiver 

applications must be approved by the EPA Regional Administrator [40 CFR 146.95(d)(2)] to 

ensure that interstate boundary and water resource issues are addressed and to contribute to 

national consistency in waiver issuance. The owner or operator must submit a waiver application 

report at the time of the initial permit application that includes the information specified in 40 

CFR 146.95(a)(1) through (7). While the waiver application report is submitted concurrently 

with the Class VI permit application, the report is not considered part of the permit application. 

The UIC Program Class VI Injection Depth Waivers Guidance provides recommendations for 

completing and evaluating the waiver application report, and the UIC Program Class VI Well 

Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators describes 

the reporting requirements associated with the waiver application process for owners or 

operators. 

The UIC Program Director is responsible for verifying that the materials in the waiver 

application report are complete as required by 40 CFR 146.95(a) and evaluating them for 

consistency and technical soundness. The UIC Program Director must also consult with the 

Public Water System Supervision (PWSS) Directors of the states and tribes in the AoR and 

provide public notice of the waiver application [40 CFR 146.95(b)(2) and 146.95(c)]. After 

receipt of public input and, if an injection depth waiver is recommended, the UIC Program 

Director must provide all information received to the EPA Regional Administrator [40 CFR 

146.95(d)]. If requested by the EPA Regional Administrator, the UIC Program Director must 

provide additional information to support his or her determination including providing additional 

public notice [40 CFR 146.95(d)(1)]. 
Draft UIC Program Class VI Well Recordkeeping, 20 March 2013 

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The UIC Program Class VI Implementation Manual for State Directors includes considerations 

for the UIC Program Director’s evaluation of the waiver application report, as well as more 

information on the consultation and public notification process. EPA has also developed a paper 

titled Additional Considerations for UIC Program Directors: Interstate Coordination 

Requirements for the Class VI Injection Well Permitting Process, which provides more 

information on interstate coordination. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information related to the waiver application process: 

• A determination of whether the information submitted in the waiver application report is

complete.

• A description of any identified deficiencies or concerns with the waiver application

report. Examples of such deficiencies may include, but are not limited to, a missing,

insufficient, or incorrect:

o Demonstration of the integrity of the upper and lower confining units and the

suitability of the injection zone(s).

o Demonstration of the lack of transmissive faults and fractures.

o Documentation of any artificial penetrations into or through the injection zone(s).

o Demonstration of storage capacity, accounting for availability of alternative

injection sites.

o Documentation of community needs, demands, and supply from drinking water

resources and documentation of planned needs and potential/future use of

USDWs and non-USDWs.

o Documentation of planned or permitted water, hydrocarbon, or mineral resource

exploitation.

o Proposed plan for securing alternative resources or treating USDWs in the event

of contamination related to Class VI activities.

o Site characterization information (see Section 2.1.2 for compliance and oversight

determinations related to site characterization).

• The UIC Program Director’s determination that the site is suitable for an injection depth

waiver (pending results of the formation testing program) or, if technical concerns cannot

be resolved, a decision that the site is unsuitable for an injection depth waiver.

• Documentation of the consultation with the applicable PWSS Director(s), including:

o Date, names, and affiliations of parties involved in the communication(s).
Draft UIC Program Class VI Well Recordkeeping, 21 March 2013 

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o Copy of the letter sent to the PWSS Directors (see the UIC Program Class VI

Implementation Manual for State Directors for a template).

o Record of other materials sent to the PWSS Directors.

o Written waiver-related information submitted by the PWSS Director(s) to the UIC

Program Director.

• Information related to public notice of the waiver application per 40 CFR 146.95(c),

including:

o A copy of the public notice.

o The date of the notification.

o The method of publication.

o A record of any public comments received and the responses from the UIC

Program Director.

• Documentation of the EPA Regional Administrator’s evaluation, such as:

o A copy of the materials submitted to the EPA Regional Administrator and the

date of submission.

o Copies of any materials sent to the EPA Regional Administrator in response to a

request for additional information and the date(s) of submission.

o Information related to additional public notice, if required by the EPA Regional

Administrator.

o A copy of the EPA Regional Administrator’s concurrence with issuance of the

waiver and the date the determination was received.

o The date of waiver issuance, if applicable.

• A copy of, or links to, information regarding the injection depth waiver that is posted on

EPA’s website, pursuant to 40 CFR 146.95(e).

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.
Draft UIC Program Class VI Well Recordkeeping, 22 March 2013 

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2.2 Pre-Injection Phase: Prior to Injection

Following the construction of a Class VI well, the UIC Program Director must review additional 

information submitted by owners or operators pursuant to 40 CFR 146.82(c) before issuing a 

final permit authorizing injection. This information is primarily related to final site 

characterization and well construction data based on the results of pre-injection testing. This 

section describes the UIC Program Director’s recommended reporting and data management 

responsibilities, related to these activities (see Table 2-1). In addition, following the decision to 

authorize injection, the UIC Program Director will retain administrative records pursuant to 40 

CFR 124.18 for final permits.

2.2.1 Site Characterization

During drilling and construction of the well, the owner or operator must execute the formation 

testing plan to collect the information required at 40 CFR 146.87 and update the preliminary 

information submitted with the initial permit application [40 CFR 146.82(c)(2) and (4)]. These 

formation testing activities are described in the UIC Program Class VI Well Site 

Characterization Guidance and the related reporting and recordkeeping activities performed by 

owners or operators are described in the UIC Program Class VI Well Recordkeeping, Reporting, 

and Data Management Guidance for Owners or Operators. 

Prior to authorizing injection, the UIC Program Director will review the well log, core, and fluid 

sampling results and compare the information to the previously submitted site characterization 

data. He or she will evaluate whether any updates to the site characterization information or 

changes to the site geologic conceptual model are sufficient to raise concerns about the integrity 

of the confining zone, alter the storage capacity estimation, or necessitate changes in planned 

operational parameters. Detailed considerations for the UIC Program Director’s evaluation are 

given the UIC Program Class VI Implementation Manual for State Directors.

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations:

• The date of receipt for all submittals.

• A description of any deficiencies or concerns. Examples of such deficiencies may

include, but are not limited to:

o Insufficiently documented procedures or results.

o Any concerns over the suitability of the site for GS based on final site

characterization data.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.
Draft UIC Program Class VI Well Recordkeeping, 23 March 2013 

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o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.2.2 Final AoR and Corrective Action Status

Prior to granting approval for injection, the UIC Program Director conducts an evaluation to 

ensure that results of formation testing and logging (as well as other updates to the site 

characterization data and the proposed operational data) are incorporated into the final 

delineation of the AoR [40 CFR 146.82(c)(1)]. Additionally, the UIC Program Director evaluates 

the status of corrective action on wells in the AoR [40 CFR 146.82(c)(6)]. Detailed information 

on how the UIC Program Director conducts the evaluation and a summary of all considerations 

for this evaluation are given in the UIC Program Class VI Implementation Manual for State 

Directors. 

The UIC Program Director should document receipt of the final AoR delineation and the 

corrective action status, noting whether the material is complete or if additional information is 

needed. For the purpose of ensuring complete and consistent compliance and oversight 

evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA 

recommends that UIC Program Directors document the following information resulting from 

their evaluations: 

• The date of receipt for all final submittals.

• For the AoR and Corrective Action Plan, if updated (in addition to the considerations

applicable to all project plans, which are addressed in Section 2.2.4):

o If applicable, the approval decision for phased corrective action, including

specific well identification information for the proposed schedule for conducting

corrective action.

o The final approved schedule for AoR reevaluations.

o The final identified site-specific and/or operational triggers for AoR reevaluations

prior to the next scheduled reevaluation.

• For the final AoR delineation:

o A determination whether the final delineation is complete, complies with the

requirements at 40 CFR 146.84(c), and adequately describes the area that will be

impacted by carbon dioxide injection at the anticipated volumes and rates.

o A description of any deficiencies identified in delineation, such as inconsistencies

between the information used in modeling and final site- and operation-specific

data based on the formation testing program results.
Draft UIC Program Class VI Well Recordkeeping, 24 March 2013 

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o The name of the computational code used for the delineation as submitted by the

owner or operator.

o The simulation period used for final AoR delineation modeling as submitted by

the owner or operator.

o Information on contractors used by the owner or operator, if applicable and

provided.

o Information on contractors used by the UIC Program Director, if applicable.

• For corrective action activities:

o Documentation of any notifications that corrective action has been conducted,

including:

 Date of the notification.

 A list of wells that received corrective action, the date the corrective

action was performed (if known), and the type of corrective action (e.g.,

plugging, remedial cementing).

o A determination of whether the list of wells that received corrective action is

complete (compared to the list submitted with the permit application) and the

corrective action is acceptable.

o A determination of whether all testing and remedial cementing records for wells

that received corrective action are complete.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any other compliance or oversight information.

2.2.3 Injection Well Construction and Testing

Prior to receiving authorization to inject, the owner or operator must submit final construction 

procedures demonstrating that the well was constructed in compliance with the requirements at 

40 CFR 146.86 [40 CFR 146.82(c)(5)]. The owner or operator must also submit a demonstration 

of mechanical integrity [40 CFR 146.82(c)(8)]. Details on injection well construction 

requirements for Class VI wells are included in the UIC Program Class VI Well Construction 
Draft UIC Program Class VI Well Recordkeeping, 25 March 2013 

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for Permitting Authorities

Guidance. The UIC Program Class VI Implementation Manual for State Directors can be 

consulted for further information on the UIC Program Director’s evaluation of this information. 

The UIC Program Director should document receipt of the materials and whether the material is

complete or additional information is needed for the purpose of ensuring complete and consistent 

compliance and oversight evaluations. EPA recommends that UIC Program Directors document 

following information resulting from their evaluations of injection well construction submittals:

• The date of receipt for all submittals.

• A determination of whether the final injection well construction procedures are consistent

with the approved plan and stimulation program, if applicable.

• If applicable, a determination that any revisions to the well construction are documented

in as-built specifications and are acceptable to ensure non-endangerment of USDWs.

• Documentation regarding the design, approval, and installation of required safety devices

and pressure monitoring gauges.

• A description of any identified deficiencies or concerns. Examples of such deficiencies

may include, but are not limited to, insufficient information on:

o Deviation checks on the well and logs showing the actual trajectory and depths of

the well.

o Logs of the drilling and cementing of the well.

o Cement setting times.

o Results of pressure tests on casings.

o Descriptions of any deviations from the approved construction procedures.

o Completion records (e.g., perforation type and location, stimulation methods

used).

• A record of any remedial work required.

• The date that well construction began.

• The date of well completion.

• The date(s) of any testing performed on the well.

• A record of approval of construction results, including pressure tests and cement bond

logs.

• A copy of any requests for additional information or related communications with the

owner or operator, including:
Draft UIC Program Class VI Well Recordkeeping, 26 March 2013 

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o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.2.4 Final Project Plans

The Class VI Rule, at 40 CFR 146.82(c)(9), requires owners or operators to submit any updates 

to the proposed project plans listed in Section 2.1.6 that are necessary based on new information 

collected during logging and testing of the well and the formations. 

It is the UIC Program Director’s responsibility to review the final project plans. Based on his or 

her review, the UIC Program Director approves the final project plans or communicates with the 

owner or operator regarding any additional information necessary to support and evaluate the 

materials. The UIC Program Class VI Implementation Manual for State Directors can be 

consulted for further information on the UIC Program Director’s evaluations. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations of the 

final proposed project plans: 

• The date of receipt for all submittals.

• A determination of whether the updated materials are complete and comply with the

requirements of the Class VI Rule (see Section 2.1.6 for Class VI Rule citations specific

to each project plan) and the date of the determination.

• Any deficiencies in the materials based on the UIC Program Director’s evaluation (e.g.,

plan does not incorporate or adequately address new site-specific information identified

during formation logging and testing).

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.
Draft UIC Program Class VI Well Recordkeeping, 27 March 2013 

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2.3 Injection Phase 

During the injection phase, the owner or operator will generate and submit monitoring, testing,

and operational data at varying intervals, including semi-annually and prior to or following 

specific events (e.g., 30-day notifications and 24-hour emergency notifications). The owner or 

operator will also submit periodic AoR reevaluations and updates to the required project plans, 

as well as updates to the financial responsibility instruments and cost estimates. The permitting 

authority is responsible for evaluating these submittals and documenting necessary compliance 

and oversight information. 

Additionally, the permitting authority will need to document data generated as a result of 

inspections or enforcement actions. This information may include: 

• Information on inspections, including the date on which an inspection was conducted, the

inspector, and the result of the inspection.

• Documentation of compliance or enforcement actions conducted (e.g., notice of violation,

administrative order, judicial action issued).

• Any response and/or remedial action that resulted from inspection and enforcement

actions.

Where permit modifications are needed pursuant to 40 CFR 144.39(a)(5) or 144.41(h) (e.g., 

based on AoR reevaluations, amendments to any of the GS project plans, annual updates to 

financial responsibility information, reviews of testing and monitoring data), information 

associated with the permit modification process will need to be recorded. This may include 

milestone data related to writing a new permit or information about the public notification 

process. 

This section describes the UIC Program Director’s recommended reporting and data 

management responsibilities associated with activities that occur in the injection phase, including 

documentation of the oversight and compliance information associated with the activities 

described above.

2.3.1 Injection Well Operation

The Class VI Rule, at 40 CFR 146.88, sets requirements for the operation of Class VI wells. 

These requirements include limitations on injection pressure, prohibition of injection between the 

outermost casing and well bore, monitoring of the annulus pressure, maintenance of mechanical 

integrity, installation of monitoring equipment and safety devices, and implementation of certain 

procedures in case of a loss of mechanical integrity. Documentation of the design, approval, and 

installation of safety devices and pressure monitoring gauges will have been provided as part of 

the well design and construction submittals (see Section 2.2.3). Recorded injection pressures will 

be submitted with the required testing and monitoring reports, as described in Section 2.3.2. 

Details on operating requirements for Class VI wells are included in the UIC Program Class VI 

Well Construction Guidance, and reporting and recordkeeping information for owners or 
Draft UIC Program Class VI Well Recordkeeping, 28 March 2013 

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operators is included in the UIC Program Class VI Well Recordkeeping, Reporting, and Data 

Management Guidance for Owners or Operators. 

It is the UIC Program Director’s responsibility to review documented operating information, 

such as information provided in the semi-annual reports, to ensure that injection well operation is 

proceeding as planned, the owner or operator is in compliance with the Class VI permit, and the 

well is not endangering USDWs. The UIC Program Class VI Implementation Manual for State 

Directors provides considerations for the UIC Program Director’s evaluation. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information related to injection well operation: 

• The date of receipt for all submittals.

• The dates and results of any pressure tests or other mechanical integrity tests (MITs).

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

Determining compliance with the injection pressure requirement will require information from 

two sources. First, the site characterization submissions will need to be reviewed to determine 

the fracture pressure of the injection zone; this should be reflected in the injection pressure limits 

stipulated in the Class VI permit. Second, the regular monitoring reports will need to be 

reviewed to ensure that the pressure did not exceed the 90 percent threshold (or a lower injection 

pressure set as a permit condition). Similar reviews will be necessary for annulus pressure 

information. EPA recommends that the UIC Program Director document the following: 

• The date of any excursions over the injection pressure limit set in the Class VI permit.

• Any actions taken as a result of pressure excursions over the permitted range.

Finally, the UIC Program Director must respond to any notification of a loss of mechanical 

integrity. If a loss of mechanical integrity or the triggering of a safety valve occurs, EPA 

recommends that the UIC Program Director document the following (see also Section 2.3.6 for 

additional information related to emergency reporting): 

• The time and date of the incident.
Draft UIC Program Class VI Well Recordkeeping, 29 March 2013 

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• How the UIC Program Director learned of the incident (e.g., documentation of received

notifications) and the time and date the incident was reported to the UIC Program

Director.

• Documentation of conversations between the UIC Program Director and the owner or

operator regarding necessary responses to the event, including approvals, if applicable.

• Actions taken by the owner or operator, including times and dates of these actions.

• Any remedial work done.

• The schedule for returning the well to service or for plugging the well.

• The dates, types, and results of tests to demonstrate that mechanical integrity has been

restored.

• The date of approval to return the well to service (and copies of any written

communications regarding this approval) and the date that injection resumed.

If well stimulation is to be performed over the course of the project, EPA recommends that the 

UIC Program Director document the following information:

• The date that the notification of the planned stimulation was received and the date of the

planned stimulation operation.

• The date of the stimulation operation.

• The results of the stimulation, including any reports submitted by the owner or operator.

2.3.2 Testing and Monitoring

The Class VI Rule, at 40 CFR 146.90, requires owners or operators to follow an approved 

Testing and Monitoring Plan to ensure that the Class VI project is operating in a manner that 

protects USDWs. Testing and monitoring requirements, at a minimum, include: analysis of the 

chemical and physical characteristics of the carbon dioxide stream, MITs, corrosion monitoring, 

monitoring the position of the carbon dioxide plume and pressure front, monitoring of 

geochemical changes in the subsurface, surface air and/or soil gas monitoring (required at the 

discretion of the UIC Program Director), and any additional tests necessary to ensure USDW 

protection. More information on the required testing and monitoring for Class VI projects can be 

found in the UIC Program Class VI Well Testing and Monitoring Guidance. 

The Class VI Rule, at 40 CFR 146.91, requires owners or operators to submit testing and 

monitoring data in semi-annual reports, within 30 days of conducting testing, and/or in 24-hour 

notifications, depending on the type of information. Reporting and recordkeeping requirements 

associated with testing and monitoring are discussed in the UIC Program Class VI Well 

Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. Detailed 

information the UIC Program Director’s evaluation of this information can be found in the UIC

Program Class VI Implementation Manual for State Directors. 
Draft UIC Program Class VI Well Recordkeeping, 30 March 2013 

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For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations of 

testing and monitoring results:

• The date of receipt and type of submission (semi-annual report, 30-day

notification/report, or 24-hour notification).

• A determination of whether the submitted documentation is complete and complies with

the requirements under 40 CFR 146.90 and 146.91.

• A description of any deficiencies or concerns. These deficiencies may include missing

information or insufficiently documented procedures or results of the specific testing and

monitoring activities listed under 40 CFR 146.90.

• A determination of whether the testing and monitoring results indicate exceedance of a

permitted parameter, carbon dioxide excursion, or USDW endangerment; whether an

AoR reevaluation is warranted; and whether monitoring results for the injected carbon

dioxide plume and/or the associated pressure front differ significantly from model

predictions.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.3.3 Reevaluation of AoR and Phased Corrective Action

During the injection and post-injection phases, owners or operators of permitted Class VI wells 

are required to reevaluate the AoR delineation on a regular basis, at a frequency determined in 

the AoR and Corrective Action Plan (at least once every five years) [40 CFR 146.84(e)]. The 

Class VI Rule requires owners or operators to revise the AoR and Corrective Action Plan if a 

revision of the AoR delineation is necessary following a reevaluation [40 CFR 146.84(e)(4)]. It 

is important to note that a change in the AoR and/or the AoR and Corrective Action Plan after 

the permit is issued may constitute a modification of the UIC permit. Additionally, if the UIC 

Program Director has authorized a phased corrective action approach for a given Class VI 

project, the owner or operator will submit documentation of completed corrective action

activities. 

More information on periodic AoR reevaluations, revisions to the AoR and Corrective Action 

Plan, and phased corrective action is given in the UIC Program Class VI Well Area of Review 
Draft UIC Program Class VI Well Recordkeeping, 31 March 2013 

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Evaluation and Corrective Action Guidance. Reporting and recordkeeping information specific 

to owners or operators is described in the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Owners or Operators. Detailed information on 

the UIC Program Director’s evaluation and a summary of considerations for this evaluation are 

given in the UIC Program Class VI Implementation Manual for State Directors. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations:

• For AoR reevaluations:

o The date of the reevaluation and the submission.

o The reason for reevaluation (i.e., planned or triggered).

o A determination of whether the AoR and Corrective Action Plan must be

amended.

o A determination of whether additional corrective action is needed, including (if

applicable) a list of wells needing corrective action that are not identified in the

approved AoR and Corrective Action Plan.

• For the revised AoR delineation:

o A determination of whether the revised delineation is complete and complies with

the requirements under 40 CFR 146.84(c).

o A description of any deficiencies identified in the delineation, such as

inconsistencies identified between the information used in modeling and updated

site- and operation-specific data based on the formation testing program results.

o A decision on the appropriateness of the modeling approach and its compliance

with the Class VI Rule.

o Information on contractors used by the owner or operator, if applicable and

provided.

o Information on contractors used by the UIC Program Director, if applicable.

• If an amendment to the AoR and Corrective Action Plan is needed (in addition to the

considerations applicable to all project plans, which are addressed in Section 2.3.4):

o Documentation of changes to the size or shape of the AoR.

o Documentation of any necessary changes to the phased corrective action

schedule, if applicable.
Draft UIC Program Class VI Well Recordkeeping, 32 March 2013 

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o Whether the list of wells requiring corrective action is complete, based on the UIC

Program Director’s knowledge of pertinent well databases (i.e., an assessment of

whether the owner or operator consulted all applicable information sources).

• For phased corrective action activities:

o Documentation of any notifications that corrective action has been conducted,

including:

 Date of the notification.

 A list of wells that received corrective action during the current phase, the

date that corrective action was performed (if available), and the corrective

action completed (e.g., plugging, remedial cementing).

o Whether corrective action has been completed for all wells in the current phase

(compared to the wells identified in the AoR and Corrective Action Plan).

o A determination whether all testing and remedial cementing records for wells that

received corrective action submitted are complete.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.3.4 Project Plan Updates

Owners or operators must periodically review the AoR and Corrective Action, Testing and 

Monitoring, and Emergency and Remedial Response Plans and update them if necessary based 

on operating or monitoring data or the most recent AoR reevaluation [40 CFR 146.84(e)(4), 

146.90(j), and 146. 94(d), respectively]. These reviews occur after AoR reevaluations, based on 

testing and monitoring data, and/or following changes to the facility, as well as when required by 

the UIC Program Director. The Class VI Rule does not require formal periodic reviews and 

amendments of the Injection Well Plugging Plan or the PISC and Site Closure Plan during the 

injection phase; however, EPA recommends that owners or operators and the UIC Program 

Director communicate regarding potential changes to these plans. More information on 

completing and documenting plan updates can be found in the UIC Program Class VI Well 

Project Plan Development Guidance and the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Owners or Operators. 
Draft UIC Program Class VI Well Recordkeeping, 33 March 2013 

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The UIC Program Director’s responsibilities include reviewing amendments to the project plans. 

Based on his or her review, the UIC Program Director approves the amended project plans or 

communicates with the owner or operator regarding any additional information necessary to 

support and evaluate the plan updates. Amended plans must be incorporated into the permit and 

are subject to the permit modification requirements under 40 CFR 144.39 and 144.41, depending 

on the extent of the updates. The UIC Program Class VI Implementation Manual for State 

Directors includes more information on plan amendments and permit modifications, as well as 

additional considerations for UIC Program Directors. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations: 

• The submission date of an amended plan or demonstration that no amendment is

necessary.

• The reason for the review of the plan(s) (e.g., AoR reevaluation, facility change, UIC

Program Director requirement), including the date of the associated AoR reevaluation, if

applicable.

• A determination of whether the amended plan(s) are complete and comply with the

requirements of the Class VI Rule.

• A summary of significant changes to any of the plans, such as:

o Additional corrective action needs.

o Revision of the alternative PISC timeframe.

o Additional testing and/or monitoring.

o New emergency and remedial response procedures.

• The result of the review of the revised plan(s) and the date of the determination.

• Documentation of whether a permit modification is required, and whether the

modification will be issued under 40 CFR 144.39 or 40 CFR 144.41(h).

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.
Draft UIC Program Class VI Well Recordkeeping, 34 March 2013 

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2.3.5 Financial Responsibility Updates and Notifications 

On an annual basis, the owner or operator must adjust the cost estimate of the required GS 

activities for inflation [40 CFR 146.85(c)(2)]. Owners or operators must also revise cost 

estimates as necessary based on any needed amendments to the AoR and Corrective Action Plan, 

the Injection Well Plugging Plan, the PISC and Site Closure Plan, or the Emergency and 

Remedial Response Plan [40 CFR 146.85(c)(3)] and provide notifications of adverse financial 

conditions [40 CFR 146.85(d)]. More information on financial responsibility updates and 

notifications is provided in the UIC Program Class VI Well Financial Responsibility Guidance

and associated reporting and recordkeeping activities for owners or operators are described in the 

UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for 

Owners or Operators. 

Over the lifetime of the project, it is the UIC Program Director’s responsibility to review and 

document the updated cost estimates, verify that they are accurate, and ensure that qualified 

independent third-party instruments or self insurance are sufficient to cover the estimated costs. 

Detailed information on the UIC Program Director’s evaluation, including a summary of 

considerations, is given in the UIC Program Class VI Implementation Manual for State 

Directors. 

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations of 

financial responsibility information: 

• The date of receipt for all submittals.

• The reason for the submittal (e.g., to fulfill the annual cost estimate update requirement,

in response to changes in a project plan).

• The date of the UIC Program Director’s review of revised cost estimates or financial

responsibility instruments and a determination of whether the updated cost estimate is

complete and financial responsibility instruments remain adequate.

• A description of any deficiencies or concerns. Examples of such deficiencies may

include, but are not limited to, insufficient documentation of:

o Additional financial responsibility instruments obtained following an increase in

the current cost estimate.

o Specific activities that have been completed to request release from a financial

responsibility instrument.

o Methods to complete cost estimate updates and adjustment for inflation.

• Any documentation releasing the owner or operator from a financial instrument following

completion of specific activities.
Draft UIC Program Class VI Well Recordkeeping, 35 March 2013 

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• Documentation of any requests to adjust a cost estimate.

• Documentation of any notifications of adverse financial conditions.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.3.6 Emergency and Remedial Response

If the owner or operator obtains evidence of any event or circumstance that may cause 

endangerment to USDWs, he or she must complete the activities specified in the Class VI Rule 

at 40 CFR 146.94(b). These include immediately ceasing injection, working to identify and 

characterize any release, notifying the UIC Program Director within 24 hours, and implementing 

the approved Emergency and Remedial Response Plan. The UIC Program Director may 

authorize the owner or operator to resume injection prior to remediation if the owner or operator 

demonstrates that injection will not endanger USDWs [40 CFR 146.94(c)]. Reporting and 

recordkeeping requirements for owners or operators associated with emergency and remedial 

response are discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data 

Management Guidance for Owners or Operators. See Section 2.3.1 for additional information on 

reporting associated with a loss of mechanical integrity.

In the event of an emergency, the UIC Program Director will communicate with the owner or 

operator to ensure that appropriate response actions are implemented and that USDWs are 

protected. If applicable, the UIC Program Director will also review the owner or operator’s 

demonstration that resuming injection prior to remediation will not endanger USDWs. More 

information on the UIC Program Director’s responsibilities and evaluations is given in the UIC

Program Class VI Implementation Manual for State Directors.

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations:

• The date and time of receipt of any emergency notifications from the owner or operator

and a brief description of any incident.

• A record of communications with the owner or operator regarding the incident, including:

o The date of the communication.
Draft UIC Program Class VI Well Recordkeeping, 36 March 2013 

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o The format of the communication (and a copy, if applicable).

o The names and affiliations of parties involved in the communication.

• A determination of whether all appropriate activities specified in the Emergency and

Remedial Response Plan are conducted.

• Documentation of any impacts on a USDW.

• A decision regarding whether remediation is required and a description of the necessary

remedial action(s).

• A determination of whether materials received to demonstrate that resuming injection

prior to remediation will not endanger USDWs is complete and sufficient.

• A description of any deficiencies or concerns regarding submitted materials.

• A determination regarding the resumption of operations and the date that injection

resumes.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.4 Post-Injection Phase

Following cessation of injection, owners or operators will submit various materials, such as an 

injection well plugging report, PISC monitoring data, a non-endangerment demonstration, and a 

site closure report. The UIC Program Director will need to evaluate each submittal and document 

that it is acceptable and/or how deficiencies were addressed.

This section describes these post-injection phase activities and summarizes recommended 

documentation to support compliance and oversight decisions and the process of adaptive 

rulemaking. 

2.4.1 Injection Well Plugging

The Class VI Rule, at 40 CFR 146.92, establishes minimum technical criteria for injection well 

plugging. At least 60 days prior to plugging, the owner or operator must notify the UIC Program 

Director of intent to plug the well [40 CFR 146.92(c)]. If the original Injection Well Plugging 

Plan has been revised, the owner or operator must also provide the revised plan at this time. 
Draft UIC Program Class VI Well Recordkeeping, 37 March 2013 

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Within 60 days after plugging, the owner or operator must submit a well plugging report [40 

CFR 146.92(d)]. A more complete discussion of well plugging requirements and 

recommendations can be found in the UIC Program Guidance on Class VI Well Plugging, PostInjection Site Care, and Site Closure. A description of reporting and recordkeeping requirements 

for owners or operators is provided in the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Owners or Operators. 

Upon receipt of the injection well plugging report, the UIC Program Director is responsible for 

verifying that all proposed and approved plugging activities have been properly executed. If the 

plugging activities deviated from the approved Injection Well Plugging Plan, EPA recommends 

that the UIC Program Director request additional information from the owner or operator. More 

details regarding the UIC Program Director’s responsibilities during the well plugging process

can be found in the UIC Program Class VI Implementation Manual for State Directors. 

UIC Program Directors should document their evaluations in order to ensure compliance with 

the Class VI Rule and consistency in implementation and oversight decisions. EPA recommends 

that UIC Program Directors document the following for their evaluations of injection well 

plugging: 

• The date of receipt of the notice of intent to plug the injection well.

• The date of receipt of the amended Injection Well Plugging Plan, if applicable, and:

o A determination of whether the amended plan is complete and complies with the

requirements of the Class VI Rule.

o The result of the evaluation and the date of the determination.

o Documentation of whether a permit modification is required.

• The planned date on which the injection well is to be plugged and whether this will be

witnessed by the UIC Program Director.

• A description of any deficiencies or concerns. Examples of such deficiencies may

include, but are not limited to, insufficient documentation of:

o Reading final pressure from downhole pressure transducer.

o Removal of well components, injection tubing and obstructions.

o Well flushing.

o External MIT.

• For the injection well plugging report:

o The date of receipt of the report.
Draft UIC Program Class VI Well Recordkeeping, 38 March 2013 

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o A determination of whether the report is complete and submitted pursuant to the

requirements under 40 CFR 146.92(d), and whether the well was tested and

plugged in accordance with the Injection Well Plugging Plan.

o A description of any identified deficiencies in the report.

• Information on contractors used by the owner or operator, if applicable and provided.

• Information on contractors used by the UIC Program Director, if applicable.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any other compliance or oversight information.

2.4.2 PISC and Site Closure

Following well plugging, owners or operators must carry out PISC monitoring as specified in the 

PISC and Site Closure Plan and ultimately close the site [40 CFR 146.93]. During the PISC 

period, the UIC Program Director will receive and review monitoring data submitted by the 

owner or operator to ensure that the carbon dioxide plume and associated pressure front are 

behaving as predicted and are not causing endangerment to USDWs. The owner or operator will 

also continue to conduct AoR reevaluations according to the schedule in the AoR and Corrective 

Action Plan (see Section 2.3.3 for more information on AoR reevaluation reporting). EPA 

expects that most reevaluations in the post-injection phase will not result in changes to the AoR 

delineation or the AoR and Corrective Action Plan. 

Prior to authorization for site closure, the owner or operator must submit a demonstration that no 

additional monitoring is needed to ensure that the project does not pose an endangerment to 

USDWs [40 CFR 146.93(b)(3)]. If the demonstration is approved, the site can be closed. Owners 

or operators must submit a notice of intent for site closure (and a revised PISC and Site Closure 

Plan, if applicable) at least 120 days before closing the site [40 CFR 146.93(d)]. Following site 

closure, the owner or operator must submit a report pursuant to [40 CFR 146.93(f)]. 

At the end of the PISC period, the UIC Program Director’s responsibilities include evaluating the 

non-endangerment demonstration (including the revised PISC and site closure plan, if 

applicable). If the UIC Program Director determines, based on the data presented, that the plume 

and pressure have stabilized and that the site does not pose a risk to USDWs, he or she may 

authorize site closure. The UIC Program Director will also need to review documents associated 

with site closure, including the notice of intent for site closure and site closure report. 
Draft UIC Program Class VI Well Recordkeeping, 39 March 2013 

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Detailed information on PISC and site closure is provided in the UIC Program Guidance on 

Class VI Well Plugging, Post-Injection Site Care, and Site Closure. Associated reporting and 

recordkeeping requirements for owners or operators are described in the UIC Program Class VI 

Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. 

Detailed information on the UIC Program Director’s evaluation, including a summary of 

applicable considerations, is given in the UIC Program Class VI Implementation Manual for 

State Directors.

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the following information resulting from their evaluations:

• The date of receipt for all submittals.

• For PISC:

o A determination whether the approved PISC and Site Closure Plan needs to be

updated and, if so, documentation of the revised plan (e.g., date of submission,

any identified deficiencies, result of the UIC Program Director’s determination,

the date of the determination).

o Documentation of the receipt and review of all monitoring data, including the date

of the submittal, and whether the results confirm predictions about the carbon

dioxide plume and pressure front and that no USDW endangerment is indicated.

o A determination of whether the submitted documentation is complete and

consistent with the requirements under 40 CFR 146.93 and the approved PISC

and Site Closure Plan.

o A description of any deficiencies or concerns. These deficiencies may include

missing information, insufficiently documented procedures, or the results of

specific monitoring activities.

o A determination of whether a revision to the PISC monitoring is needed (e.g., if

monitoring results indicate at any point during PISC that the position of the

carbon dioxide plume and/or the associated pressure front are different than what

was predicted by modeling and described in the approved PISC and Site Closure

Plan).

o Any additional compliance or oversight information.

• For the non-endangerment demonstration:

o The date of submission.

o A determination of whether the submitted documentation is complete and

complies with the requirements under 40 CFR 146.93.
Draft UIC Program Class VI Well Recordkeeping, 40 March 2013 

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o A description of any deficiencies or concerns. These deficiencies may include

missing information, insufficiently documented procedures, poor agreement

between monitoring data and model predictions, or a trend of increasing total

dissolved solids (TDS) or other constituents in overlying formations or USDWs.

o An indication of whether site closure is authorized or further PISC is needed, and

the date of this determination.

• For site closure:

o Date of submission of the notice of intent for site closure.

o The planned date(s) of site closure-related activities (e.g., monitoring well

plugging) and whether any will be witnessed by the UIC Program Director.

o Date of submission of site closure report, and:

 A determination of whether the submitted documentation is complete and

compliant with the requirements under 40 CFR 146.93(f).

 A description of any deficiencies or concerns, such as insufficient

documentation of the plugging of monitoring wells or notifications to

applicable parties.

• Documentation that the owner or operator has properly filed survey plats and facility

property deed notations and that state, local and tribal authorities that have authority over

drilling activities have been notified.

• Information on contractors used by the owner or operator, if applicable and provided.

• Information on contractors used by the UIC Program Director, if applicable.

• A copy of any requests for additional information or related communications with the

owner or operator, including:

o The date of the request.

o The names and affiliations of parties involved in the communication.

o Documentation of resolution of issues raised in the request for additional

information.

• Any additional compliance or oversight information.

2.4.3 Emergency and Remedial Response

As with the injection phase, the owner or operator must carry out emergency notification and 

remedial response activities if there is evidence of endangerment to USDWs [40 CFR 

146.94(b)]. While the requirement to cease injection does not apply to the post-injection phase, 
Draft UIC Program Class VI Well Recordkeeping, 41 March 2013 

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the owner or operator must still work to identify and characterize any release, notify the UIC 

Program Director within 24 hours, and implement the approved Emergency and Remedial 

Response Plan. Emergency and remedial response reporting and recordkeeping for owners or 

operators is discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data 

Management Guidance for Owners or Operators.

In the event of an emergency, the UIC Program Director will communicate with the owner or 

operator to ensure that appropriate response actions are implemented and that USDWs are 

protected. More information on the UIC Program Director’s responsibilities and evaluations is 

given in the UIC Program Class VI Well Implementation Manual for State Directors.

For the purpose of ensuring complete and consistent compliance and oversight evaluations and 

supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC 

Program Directors document the information listed in Section 2.3.6 (with the exception of 

information related to determining whether injection may resume before remediation, which 

would not apply in the post-injection phase). 

2.5 UIC Program Director Program Reporting to EPA 

In addition to reviewing data submitted by owners or operators, UIC Program Directors also 

report to EPA on the status of their programs. This section discusses the type of information that 

is submitted to EPA by UIC Program Directors to respond to information requests and perform 

analyses for EPA management, the Office of Management and Budget (OMB), the U.S. 

Government Accountability Office (GAO), Congress, and the public. EPA oversees primacy 

programs by using submitted reports to track, evaluate, and report on program performance. 

For the purposes of national program oversight, the UIC Program Director is required to prepare 

quarterly and annual reports associated with noncompliance to submit to the EPA Regional 

Administrator in cases where a State Director is the permitting authority or to EPA Headquarters 

in cases where EPA is the permitting authority [40 CFR 144.8]. 

Quarterly reporting is required for compliance evaluation and significant noncompliance. 

Quarterly reporting includes a list of noncomplying permittees’ names, locations, and permit 

numbers and information on violations, enforcement actions, and the number of wells returned to 

compliance, as required under 40 CFR 144.8, as well as the following, for each entry:

• A brief description and date of each instance of noncompliance. Instances of

noncompliance to be reported under 40 CFR 144.8(a)(2) are:

o Failure to complete construction elements.

o Modifications to schedules of compliance.

o Failure to complete or provide compliance schedule or monitoring reports.

o Deficient reports.
Draft UIC Program Class VI Well Recordkeeping, 42 March 2013 

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o Noncompliance with other permit requirements.

o All other instances of noncompliance.

• The date(s) and description(s) of each enforcement action taken by the UIC Program

Director.

• The date compliance was achieved.

All quarterly reports are submitted within the federal fiscal year and must be made available to 

the public on the date of submission [40 CFR 144.8(c)]. 

Annual reporting is required for permit review and issuance, mechanical integrity testing and 

remedial actions, and well inventory. Annual well inventory reports are submitted in February; 

all remaining annual reports are submitted at the end of the federal fiscal year. 

Additionally, for Class VI operations, EPA may track the following types of information on 

injection wells:

• Information on permit determinations (e.g., the number of permits issued and not issued,

permit modifications) and permit file reviews.

• Enforcement actions, including administrative actions and civil and criminal actions.

• Operators of injection wells identified as being in significant noncompliance (SNC) with

statutory and regulatory requirements, enforcement actions against SNCs, and returns of

wells to compliance; contamination of USDWs; and closures.

• Wells that have remained in SNC for two or more consecutive quarters and have not been

returned to compliance or been subject to a formal enforcement action.

In addition, EPA’s 2011–2015 Strategic Plan contains the following key Strategic Target: “By 

2015, 90 percent of community water systems will provide drinking water that meets all 

applicable health-based drinking water standards through approaches including effective 

treatment and source water protection.”4 EPA developed Program Activity Measures (PAMs) to 

assess progress toward the strategic goal, including two that are specific to Class VI wells:

• Volume of carbon dioxide sequestered through injection as defined by the Class VI Rule.

• Number of permit decisions during the reporting period that result in carbon dioxide

sequestered through injection as defined by the Class VI Rule.

4 U.S. EPA. 2010. Fiscal Year 2011–2015 EPA Strategic Plan: Achieving Our Vision. Available online at: 

http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P1008YOS.txt. 
Draft UIC Program Class VI Well Recordkeeping, 43 March 2013 

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Permitting authorities will compile information to respond to mid-year and end-of-year requests 

from EPA Headquarters for PAMs data.

2.6 Recordkeeping by the UIC Program Director

The only recordkeeping requirement specific to UIC Program Directors in the Class VI Rule 

pertains to PISC monitoring records. Following retention of PISC records for 10 years following 

site closure, owners or operators must, pursuant to 40 CFR 146.93(h), deliver these records to the 

UIC Program Director. The UIC Program Director must then designate a location for these 

records to be retained thereafter.

EPA recommends that the UIC Program Director retain all records outside of the electronic data 

system for the lifetime of the Class VI project.
Draft UIC Program Class VI Well Recordkeeping, 44 March 2013 

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3 GS Data Submission and Management 

Note: At the time this draft document was published, the central data system for Class VI data 

was under development. To avoid publishing incomplete information, this draft contains a 

placeholder for the description of GS data management through the use of the central data 

system.
Draft UIC Program Class VI Well Recordkeeping, A-1 March 2013 

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Appendix A. Draft Class VI Oversight and Compliance Data Elements Matrix

Table A-1 lists oversight and compliance data elements associated with the Class VI rule requirements for each GS project phase, 

along with potential values or types of submittals for each data element. The table is organized according to the content of the Class 

VI Rule Subpart H requirements, beginning with the permit application submissions. 

Table A-1. Class VI Rule oversight and compliance data elements matrix (DRAFT).

Compliance/Oversight Data Element Notes/Potential Values

PRE-INJECTION PHASE 

Prior to the issuance of a permit for the construction or conversion of a new Class VI well or the conversion of a Class I, Class II, or Class V well to a Class 

VI well

Permit/Facility Information

Date; Permit information may also include UIC 

Database element Ownership_Type (Type of 

ownership for a UIC well)

Permit Application submission date

Permitting Authority/Permit Agency Specific Primacy state or DI program

Permit Number

Name of the project that the permit is 

submitted for Project Name

Planned duration of project

Permit Applicant

Project Contact
Draft UIC Program Class VI Well Recordkeeping, A-2 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

Facility Information (§146.82(a)(1))

(1) The permitted activities 

(2) Name, mailing address, and location of the facility

(3) Up to four Standard Industrial Classification (SIC) codes 

(4) The operator’s name, address, telephone number, ownership status, and status as federal, state, 

private, public, or other entity 

(5) Whether the facility is located on Indian lands

(6) A listing of all permits or construction approvals: Authorization status, Permit action type, and Permit 

action date

Facility information may also include UIC 

Database elements of: 

Facility ID, Facility-State, Facility-City, FacilityZip, Facility-Street, Facility-Type, NAICS-Code, 

Petition-Status, SIC-Code

Facility Type

Injection well location Latitude and longitude

List of contacts for those states, tribes, and territories within the AoR submitted? Complete? Yes, No

Complete, non-complete 

Permit application complete?

Yes, No

Alternatively, a set of permitting milestones 

might be tracked:

• Date UIC permit scheduled to be

submitted

• Draft UIC permit issued

• Public comment period begins

• Method of public notification

• Public hearing

• Public comment period closes

• Region/state sends comments to

applicant on official permit application

(if needed)

• Region/state receives revised permit

application (if needed)

• Final UIC permit issued

Permit Writer Name of the person
Draft UIC Program Class VI Well Recordkeeping, A-3 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

The UIC Program Director’s Public Notice of Draft Permit A PDF copy of the notice

Any other information requested by the UIC Program Director Yes, No

Type of additional information requested

Are injection zone(s) of sufficient areal extent, thickness, porosity, and permeability to receive the total 

anticipated volume of carbon dioxide stream? Yes, No

NOTE: These may need to 

be separated into more 

specific elements to ensure 

that §146.83 is satisfied

Are confining zone(s) free of transmissive faults or fractures and of sufficient areal extent and integrity 

to contain the injected carbon dioxide stream and displaced formation fluids and allow injection at 

proposed maximum pressures and volumes without initiating or propagating fractures in the confining 

zone(s)?

Yes, No

The UIC Program Director requires owner or operator to identify and characterize additional zones that 

will impede vertical fluid movement, are free of faults and fractures that may interfere with 

containment, allow for pressure dissipation, and provide additional opportunities for monitoring, 

mitigation, and remediation?

Yes, No

Permit Application Status Construction authorized, Construction not 

authorized

Site Characterization Information

Submitted Information on geologic structure and hydrogeologic properties of storage site and overlying 

formations (§146.82(a)(3)) Complete, non-complete

Injection zone(s) Injection formation name

Confining zone(s) Confining formation names

Fracture pressure(s) (for a given location/formation)

This is used to oversee the requirement of 

injection pressure does not exceed 90% of this

value

Identified fracture(s); location(s); orientation(s) Complete, non-complete

Identified fault(s); location(s); orientation(s) Complete, non-complete

Geomechanical information Complete, non-complete
Draft UIC Program Class VI Well Recordkeeping, A-4 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

Seismic history information Complete, non-complete

Maps and cross-sections Complete, non-complete

AoR Delineation and Corrective Action Information

A map showing the injection well for which the permit is sought and the applicable AoR consistent with 

§146.84 (§146.82(a)(2))

• Number, name and location of all injection wells, producing wells, abandoned wells, plugged wells,

or dry holes, deep stratigraphic boreholes.

• State or EPA approved subsurface cleanup sites

• Surface bodies of water, springs

• Surface and subsurface mines, quarries

• Water wells

• Other pertinent surface features (e.g. roads, etc.)

• Faults known or suspected

Complete, non-complete

Simulator/code used for the computational modeling Code name

Identified penetrations into the injection zone(s) and confining zone(s) List of penetrations

A tabulation of all wells within AoR (§146.82(a)(4)) (well type, construction, date drilled, location, depth, 

record of plugging) Complete, non-complete

Wells requiring corrective action

Total number, each well identification/location

UIC Database also include AoR_Well (number of 

wells identified in AoR requiring corrective 

action)

NOTE: Data system may need to track the status 

of each well needing corrective action

Maps and stratigraphic cross sections of all USDWs, water wells and springs within the AoR 

(§146.82(a)(5)) Complete, non-complete

Phased corrective action proposed/authorized? Yes, No; 

Authorized, not authorized
Draft UIC Program Class VI Well Recordkeeping, A-5 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

The minimum fixed frequency to reevaluate AoR (proposed in the AoR and Corrective Action Plan) 

submitted? Sufficient frequency?

Yes, No

Yes, No

Baseline Data

Submitted baseline geochemical data on subsurface formations, including all USDWs in AoR 

(§146.82(a)(6)) Complete, non-complete

Submitted surface air and/or soil gas baseline concentrations (if required by the UIC Program Director)

Complete, non-complete

NOTE: The data element tracking if this 

monitoring required is listed under the testing 

and monitoring section

Proposed Operating Data

Average and maximum daily injection rate and volume and/or mass and total anticipated volume and/or 

mass of carbon dioxide stream total volume submitted? Yes, No

NOTE: These are not 

compliance elements in and 

of themselves; however, 

actual operating values will 

need to be consistent with 

the values in the final 

permit

Average and maximum daily injection volume and/or mass submitted? Yes, No

Total anticipated volume and/or mass of carbon dioxide stream submitted? Yes, No

Is the submitted injection rate and volume information consistent with the AoR delineation modeling? Yes, No

Average maximum injection pressure submitted? Yes, No

Source(s) of the carbon dioxide stream submitted? Yes, No

Analysis of chemical and physical characteristics of the stream submitted? Yes, No

Financial Responsibility Information

Financial responsibility demonstration Complete, non-complete

Financial responsibility establishment date

Date of the establishment of the financial 

instrument(s)

This information will be used for submitting 

annual updates

Financial responsibility sufficiently covers total costs estimated for all required phases? Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-6 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

Financial responsibility instruments Instruments (Trust Fund, Surety Bond, Letter of 

Credit, Insurance, Escrow Account, Other)

Financial responsibility institutions Institution names

Financial responsibility cost estimates

Cost values

NOTE: This information may be tracked for each 

phases, so they can be “removed” as 

completed.

Proposed Programs/Procedures

Pre-operational testing program submitted? Yes, No

Pre-operational testing program consistent with the requirements under §146.87 Yes, No

Stimulation program submitted? Yes, No

Stimulation program includes a description of fluids to be used? Yes, No

Stimulation program includes a determination that stimulation will not interfere with containment? Yes, No

Complete, non-complete

Procedure to conduct injection operation submitted? Yes, No

Proposed Plans

AoR and Corrective Action Plan submitted? 

AoR and Corrective Action Plan complete? 

AoR and Corrective Action Plan Satisfies the requirements under §146.84?

Yes, No

Complete, non-complete

Yes, No

Testing and Monitoring Plan submitted? 

Testing and Monitoring Plan complete?

Testing and Monitoring Plan Satisfies the requirements under §146.90?

Yes, No

Complete, non-complete

Yes, No

Injection Well Plugging Plan submitted? 

Injection Well Plugging Plan complete?

Injection Well Plugging Plan Satisfies the requirements under §146.92?

Yes, No

Complete, non-complete

Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-7 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

PISC and Site Closure Plan submitted? 

PISC and Site Closure Plan complete?

PISC and Site Closure Plan Satisfies the requirements under §146.93?

Yes, No

Complete, non-complete

Yes, No

Emergency and Remedial Response Plan submitted?

Emergency and Remedial Response Plan complete?

Emergency and Remedial Response Plan Satisfies the requirements under §146.94?

Yes, No

Complete, non-complete

Yes, No

Injection Well Information

Construction schematics and drawings submitted? Yes, No

Construction procedures submitted? 

Construction procedures complete?

Construction procedures satisfies the requirements under §146.86?

Yes, No

Complete, non-complete

Yes, No

Alternative PISC Timeframe Information

Alternative post-injection site care timeframe demonstration submitted? Complete? Satisfies the 

requirements under §146.93?

Yes, No

Complete, non-complete

Yes, No

Alternative PISC timeframe?

Alternative PISC timeframe consistent with PISC and Site Closure Plan? 

Alternative PISC timeframe consistent with AoR delineation modeling?

Alternative PISC timeframe approved?

Timeframe

Yes, No

Yes, No

Yes, No

Injection Depth Waiver Information

Injection Depth Waiver request submitted? Yes, No

Date that injection depth waiver request submitted? 

Date

NOTE: Concurrency with the permit application 

could be checked from dates of permit 

application and waiver application 

automatically

Injection Depth Waiver Report complete? 

Injection Depth Waiver Report satisfies the requirements under §146.95?

Complete, non-complete

Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-8 March 2013 

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Compliance/Oversight Data Element Notes/Potential Values

Request for additional information OR revised Injection Depth Waiver Report

Date of additional information request or request of revision?

Yes, No

Date 

The UIC Program Director’s Public Notice that a waiver application has been submitted A PDF copy of the notice

Consultation with PWSS Directors?

Information about the waiver forwarded to EPA Regional Administrator (RA)?

Concurrence or non-concurrence sent by the RA to the UIC Program Director

Yes, No; Date; A PDF copy of the written 

document; PDF copies of any responses 

Yes, No; Date

A PDF of copy of decision

Injection Depth Waiver Issued?

Issued, not issued

If ”Not issued”, select another site or formation, 

restart permit application

The UIC Program Director’s notification to states, tribes, or territories within the AoR based on 

§146.82(a)(2) and (19) of the permit application and pursuant to §145.23(f)(13)

A PDF copy of the notification sent to contacts 

in the list provided by o/o

Information necessary prior to UIC Program Director’s approval for operation of a Class VI well

Well construction scheduled to begin? Date NOTE: This information may be 

captured in proposed well 

construction procedures 

submitted with the permit 

application

Well construction or well reworking commences (if applicable) Date

Well construction or well reworking complete (if appropriate) Date

Final AoR submitted? Complete? Satisfies the requirements under §146.84?

Yes, No

Complete, non-complete

Yes, No

Updates to the geologic structure and hydrogeologic properties of the site submitted? Complete? Yes, No

Complete, non-complete

Information on the compatibility of the stream submitted? Complete? Yes, No

Complete, non-complete

Is the stream compatible with fluids in the injection zone(s) and minerals in both the injection and the 

confining zone(s) based on the results of the formation testing program? Yes, No

Is the stream compatible with the materials used to construct the injection well? Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-9 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

The results of the formation testing program submitted? Complete? Satisfies the requirements under 

§146.87?

Yes, No

Complete, 

noncomplete

Yes, No

NOTE: This information may 

need to be tracked test by test; 

for each test, tracked 

information could include the

test, date, and result for a list of 

tests (e.g., deviation checks, 

logs)

All logging/testing program data on the well submitted? Yes, No

Final injection well construction procedures submitted? Complete? Satisfies the requirements under 

§146.86?

Yes, No

Complete, non-complete

Yes, No

Status of corrective action for identified wells? Complete, initial phase complete, non-complete

Mechanical integrity (MI) demonstration submitted? Yes, No

MI test date(s) Date conducted

MI test(s)

MIT results [pass/fail]

Any tests witnessed by UIC Program inspectors? Yes/no; tests; date; inspector 

Specific tests used

Pass, Fail

Yes, No; Tests, Dates; Inspector Name, 

affiliation

Any updates to proposed AoR and Corrective Action Plan submitted? Yes, No

Any updates to proposed Testing and Monitoring Plan submitted? Yes, No

Any updates to proposed Injection Well Plugging Plan submitted? Yes, No

Any updates to proposed Post-Injection Site Care and Site Closure Plan submitted? Yes, No

Any updates to proposed Emergency and Remedial Response Plan submitted? Yes, No

Any updates to financial responsibility demonstration submitted? Yes, No

Any updates to injection depth waiver information submitted? Yes, No

Any updates to proposed Alternative post-injection site care timeframe demonstration submitted? Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-10 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Director approval for injection Injection authorized, non-authorized

INJECTION PHASE 

Injection well operation

The date injection commenced? Initial date of injection activity

Injection pressure within permitted levels? 

Yes, No

Values recorded with continuous recording 

devices are compared against the values in the 

permit application and the fracture pressure. 

If “No”, see emergency and violations

Injection between the casing and well bore? Yes, No

If “No”, see emergency and violations

Is the non-corrosive fluid used to fill the annulus between tubing and long string casing approved by the 

UIC Program Director? Yes, No

Does the UIC Program Director approve the annulus pressure less than the operating pressure? Yes, No

Does the annulus pressure exceed the operating pressure?

Yes, No

If last two answers are “No”, see emergency 

and violations

Are continuous recording devices installed and used for:

o Injection pressure

o Injection rate

o Volume/mass

o Temperature of the stream

o The pressure on the annulus

o Annulus fluid volume

Yes, No

If “No”, see violations

Continuous recording device description(s) Specific device brand, model, etc.

Are alarms and automatic shut-off systems installed and used? Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-11 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Does the UIC Program Director approves down-hole shut-off systems (for onshore wells), or other 

mechanical devices that provide equivalent protection? Yes, No

Automatic shut-off system description(s) Specific device brand, model, etc.

Are alarms and automatic down-hole shut-off systems installed and used for off-shore wells? Yes, No

Automatic down-hole shut-off system description(s) Specific device brand, model, etc.

Mechanical Integrity

Scheduled date of MIT

NOTE: This information could be directly pulled 

out from the permit and compared against the 

MIT date below

MI failure Yes, No

If “Yes”, see emergency and violations

MIT date Date conducted

Previous MIT date

Date conducted previously 

if MIT date-Previous MIT date < 1 year, see 

emergency and violations

Test(s) conducted

Alternate test conducted? Yes, No NOTE: Alternate methods are 

more likely to be determined 

during the permit application 

in the Testing and Monitoring 

Plan; however, there might be 

a need to adopt new methods 

during operation as well

A written request submitted by the UIC Program Director to the RA setting forth the proposed alternate 

test and all technical data submitted Yes, No

The RA approval for the alternate test? Yes, No

The alternate method published in the Federal Register Yes, No

Results of MIT submitted?

Yes, No

Date 

if Results submitted > 30 days of MIT date, see 

violations
Draft UIC Program Class VI Well Recordkeeping, A-12 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Date Results of MIT submitted?

Date

if Results submitted > 30 days of MIT date, see 

violations

Casing inspection log required? Yes, No

Scheduled date for conducting casing inspection log From permit

Date casing inspection log conducted

Date conducted

if Results submitted after due date, see 

violations

Previous casing inspection log date This must be consistent with the frequency 

approved in the Testing and Monitoring Plan

Results of casing inspection log submitted? Yes, No

Date Results of casing inspection log submitted?

Date

if Results submitted > 30 days of date 

conducted, see violations

Testing and Monitoring

Date analysis is due?

Date Injectate (carbon dioxide stream) analysis submitted

Date

Date submitted

If no date or after due date, see violations

Data sufficient for the chemical and physical characteristics? Yes, No

Yes, No

Injectate analysis parameters (measured for analyzing the stream)? Consistent with the Testing and 

Monitoring Plan? 

pH, carbon dioxide concentrations, other 

constituents

Yes, No

If “No”, see plan updates

Injectate sampling method(s) May be needed to assess the consistency if 

there is any change

Injectate analysis method(s) May be needed to assess the consistency if 

there is any change
Draft UIC Program Class VI Well Recordkeeping, A-13 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Date injectate sample is taken Date of sampling for each sample

Date injectate analysis conducted Date of actual lab analysis for each sample

Laboratory conducting the injectate analysis Laboratory name, location, contact information

Results of injectate analysis submitted (if there are any changes to the physical, chemical, and other 

relevant characteristics of the injectate from the proposed operating data) with the semi-annual 

reports?

Yes, No

If “No”, see violations

Are the following continuously monitored:

o Injection pressure

o Injection rate

o Volume/mass

o Temperature of the stream

o The pressure on the annulus

o Annulus fluid volume

Yes, No

Reporting period? Beginning date, ending date

Are recorded values consistent with the permitted values? Yes, No

If “No”, see emergency and violations

Results submitted in the semi-annual reports as:

o Monthly average, maximum and minimum values for injection pressure, flow rate, volume, and

annular pressure

o A description of any event exceeds operating parameters for annulus pressure or injection

pressure specified in the permit

o Monthly volume and/or mass of the injectate injected over the reporting period and volume

injected cumulatively over the life of the project

Yes, No

Results submitted complete? Yes, No

If “No”, see violations

Scheduled dates Corrosion monitoring (required quarterly) Date

Corrosion monitoring method? Testing method (coupons, loop, alternate 

method)
Draft UIC Program Class VI Well Recordkeeping, A-14 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Date corrosion testing conducted Date of the actual testing

Alternate corrosion monitoring method approved by the UIC Program Director? None, method

Corrosion signs observed? Yes, No

If “Yes”, see violations

Type of corrosion signs observed? None, loss of mass, loss of thickness, cracking, 

pitting, and other

Results of corrosion monitoring submitted in the semi-annual report? Yes, No

If “No”, see violations

Groundwater quality and geochemical changes monitored periodically? Yes, No

Method(s) of sampling Direct sampling, etc.

Date(s) of sampling conducted for each measurement? Date of actual sample retrieval

Date(s) of sample analysis Date of actual lab analysis

Laboratory conducting the analyses Laboratory name, location, contact information

Location and depth of each sample taken? Monitoring well location, depth

Measured/monitored parameters? pH, temperature, concentration of carbon 

dioxide, concentrations of metals, etc.

Results submitted in the semi-annual report Yes, No

If “No”, see violations

Any significant groundwater quality or geochemical changes observed? Yes, No

If “Yes” see emergency and violations

Location/time of any significant groundwater quality or geochemical changes observed compared to the 

baseline data submitted in the permit application? Monitoring well, depth

Pressure fall-off test conducted (at least once every five years or consistent with the frequency 

information approved in the Testing and Monitoring Plan) Yes, No

Estimated formation characteristics Transmissivity, others
Draft UIC Program Class VI Well Recordkeeping, A-15 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Date the pressure fall-off test conducted Date

Results submitted in the semi-annual report? Yes, No

If “No”, see violations

Any significant changes in values estimated previously and used in computational modeling Yes, No

If “Yes”, AoR reevaluation may be needed

Pressure front and plume tracking conducted? Yes, No

If “No”, see violations

Date(s) and location of monitoring of pressure front conducted? Dates and location

Date(s) and location of monitoring of plume conducted? Dates and location

Method(s) of pressure front monitoring? Specific methods used for each monitoring 

activity

Method(s) of plume monitoring? Specific methods used for each monitoring 

activity

Results submitted in the semi-annual reports? Yes, No

If “No”, see violations

Any significant difference between actual and predicted pressure front and plume? Yes, No

If “Yes”, AoR reevaluation may be needed

Does Director require surface air and/or soil gas monitoring?

Yes, No

If “No”, rest of the elements related to surface 

air and/or soil gas monitoring will not be filled.

Surface air and/or soil gas monitoring method(s) Specific methods used

Surface air and/or soil gas monitoring location(s) Specific location where testing is conducted

Surface air and/or soil gas monitoring date(s) Actual testing dates

Surface air and/or soil gas monitoring parameter(s) carbon dioxide concentrations, other

Laboratory conducting the analyses (if applicable) Laboratory name, location, contact information
Draft UIC Program Class VI Well Recordkeeping, A-16 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Results submitted in the semi-annual reports? Yes, No

If “No”, see violations

Any significant results indicating release into atmosphere or biosphere (in comparison to the baseline 

information submitted in the permit application)?

Yes, No

If “Yes”, see emergency and violations

Any additional monitoring required by the UIC Program Director (to support computational modeling)? Yes, No

Type of monitoring required?

Scheduled date for required monitoring Date

Location of monitoring?

Results submitted in the semi-annual reports or within 30 days of conducting any test of the injection 

well? Yes, No

Any significant results indicating an emergency type? Yes, No

If “Yes”, see emergency

Quality Assurance Surveillance Plan (QASP) submitted? Yes, No

If “No”, see violations

Emergency/Triggering of a Shut-Off System

Date and time of event Date, time

Notification received within 24-hour of emergency condition occurring Yes, No

If “No”, see violations

Emergency type

An endangerment to a USDW, Any noncompliance with permit condition, Any 

triggering of a shut-off system, Any failure to 

maintain MI, Any release to the atmosphere or 

biosphere

Injection ceased? Yes, No

If “No”, see violations

Response taken
Draft UIC Program Class VI Well Recordkeeping, A-17 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Leakage occurred/suspected? Yes, No

A description submitted in the semi-annual report of any event which triggers a shut-off device Yes, No

If “No”, see violations

Violations

Facility ID 

Permit ID

Permitting authority contact

Violation description MIT failure, Recordkeeping violation, etc. (as 

listed on 7520 forms)

Violation reported by Owner or Operator, Permitting Authority

Date violation occurred

Date violation reported

Date remedial action reported

Date remedial action occurred

Remedial action conducted by

Remedial action reported by

Verifying action MIT, measured values, etc.

Verification date

Notification to the UIC Program Director with the date that injection can resume submitted? Yes, No

The UIC Program Director approves the date the injection can resume? Yes, No

AoR Reevaluations and Corrective Action (Additional or Phased) 

Scheduled date of AoR reevaluations (as specified in the permit) Date

Additional corrective action need? Yes, No
Draft UIC Program Class VI Well Recordkeeping, A-18 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

List of wells that need corrective action not identified in the permit Well IDs, locations, etc.

Corrective action conducted according to the phased corrective action plan approved with the permit? Yes, No

If “No”, see emergency and violations

List of wells that received corrective action based on the phased corrective action plan Well IDs, locations, etc.

Date AoR reevaluation submitted? Date

If date after scheduled date, see violations

Was reevaluation scheduled? Yes, No

If “No”, what was trigger?

Demonstration of no amendment need submitted? Yes, No

An amendment to the AoR and Corrective Action Plan submitted? Yes, No

The UIC Program Director approves the amendment or the demonstration for no amendment need

The approved amendment is incorporated into the permit 

Yes, No

If “Yes”, other plans and financial responsibility 

need to be reviewed

NOTE: A “Permit versioning” data element may 

need to be created for tracking the process for 

each modification: draft permit, date of public 

notice, final permit

Other Plan Updates

Date demonstration of no amendment need for the reviewed Testing and Monitoring Plan submitted? Date

Date amendment to the reviewed Testing and Monitoring Plan submitted? Date

Date Director approves the amended Testing and Monitoring Plan or the demonstration for no 

amendment need Date

Date demonstration of no amendment need for the reviewed Emergency and Remedial Response plan 

submitted? Date

Date amendment to the reviewed Emergency and Remedial Response Plan submitted? Date
Draft UIC Program Class VI Well Recordkeeping, A-19 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

Date Director approves the amended Emergency and Remedial Response Plan or the demonstration for 

no amendment need Date

Review the Well Plugging Plan Yes, No

Review the PISC and Site Closure Plan Yes, No

The approved amendment is incorporated into the permit 

Yes, No 

If “Yes”, other plans and financial responsibility 

need to be reviewed

NOTE (same as in previous section): A “Permit 

versioning” data element may need to be 

created for tracking the process for each 

modification: draft permit, date of public 

notice, final permit

Financial Responsibility

Date financial responsibility demonstration update due Date

Annual financial responsibility cost estimates submitted (within 60 days prior to the anniversary date of 

the establishment; within 60 days of any amendments to the plans; and when required by the UIC 

Program Director)?

Date 

If no date or after due date, see violations

Notification of an adverse financial condition? Yes, No

The UIC Program Director approves the cost estimates? Yes, No

Adjust the face amount of financial assurance instrument(s) Yes, No

The UIC Program Director approves the instrument(s) Yes, No

Recordkeeping

The UIC Program Director requires a certain submittal to be resubmitted? Yes, No

Required information? Specific submittal

Required information resubmitted? Yes, No

If “No”, see violations
Draft UIC Program Class VI Well Recordkeeping, A-20 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

POST-INJECTION PHASE

Injection ceased? Date 

If “No”, see the “Injection Phase”

Date notice of intent to plug submitted (at least 60 days prior to plugging)? Date

The Injection Well Plugging Plan submitted with the notice of intent to plug (if any changes have been 

made to the original Injection Well Plugging Plan)? Yes, No

The UIC Program Director approves a shorter notice period? Yes, No

If approved, length of the shorter period?

The date the notice of intent to plug is submitted

The date the Injection Well Plugging Plan submitted (if revised)

The date the injection well plugged

Date plugging report submitted (within 60 days after plugging)? Date

If > 60 days, see violations

PISC and Site Closure

Submit an amended PISC and Site Closure Plan, or demonstrate no amendment needed? Amended plan, no amendment demonstration

Submitted plan or demonstration approved by the UIC Program Director? Date 

Monitor the site (at least 50 years, or for the duration of the alternative timeframe approved in the 

permit) Yes, No

Monitoring consistent with the PISC and Site Closure Plan? Yes, No

Date and location of monitoring activities submitted Date

Results of monitoring activities submitted in semi-annual reports? Date

Any significant results indicating an emergency type? Yes, No

If “Yes”, see emergency and violations

A non-endangerment demonstration submitted? Date 
Draft UIC Program Class VI Well Recordkeeping, A-21 March 2013 

Reporting, and Data Management Guidance 

for Permitting Authorities

Compliance/Oversight Data Element Notes/Potential Values

The UIC Program Director approves the non-endangerment demonstration

Yes, No

If “No”, PISC and Site Closure Plan may need to 

be amended

If non-endangerment demonstration is not approved, an amendment to the PISC and Site Closure Plan or 

no amendment needed demonstration submitted?

Yes, No

If “No”, see violations

The UIC Program Director approves the amendment or no amendment needed demonstration Date

If non-endangerment demonstration is approved, a notice of intent for site closure is submitted (at least 

120 days before site closure) Yes, No

The UIC Program Director authorizes the site closure? Yes, No

Date of site closure The date for the completion of plugging all 

monitoring wells, and restoring site

A site closure report submitted (within 90 days of site closure) Date

If > 90 days, see violations

The UIC Program Director approves the site closure report Date

A notation on the deed to the facility property is recorded Date 

If no date, see violations